SEPA
            United States
            Environmental Protection
            Agency
            Environmental Monitoring
            and Support Laboratory
            PO BOK 15027
            Las Vegas NV89114
EPA 600 7 78-228
November 1978
            Research and Development
Regulatory Water
Quality Monitoring—
A Systems Perspective

Interagency
Energy-Environment
Research
and Development
Program Report

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                  RESEARCH REPORTING SERIES

Research reports of the Office of Research and Development.  US Environmental
Protection Agency, have been grouped into nine series. These nine  broad categories
were established to facilitate further development and application of environmental
technology.  Elimination of traditional grouping was  consciously planned to foster
technology transfer and a maximum interface in related fields.  The nine series are

       1.  Environmental Health Effects Research
       2.  Environmental Protection Technology
       3.  Ecological Research
       4   Environmental Monitoring
       5   Socioeconomic Environmental Studies
       6   Scientific and Technical Assessment Reports (STAR)
       7.  Interagency Energy-Environment Research and Development
       8.  "Special" Reports
       9.  Miscellaneous Reports
This report  has been  assigned  to  the  INTERAGENCY ENERGY—ENVIRONMENT
RESEARCH AND DEVELOPMENT series  Reports in this series result from the effort
funded under the 17-agency Federal Energy/Environment Research and Development
Program. These studies relate to EPA'S mission to protect the public health and welfare
from adverse effects of pollutants associated with energy systems The goal of the Pro-
gram is to assure the rapid development of domestic energy supplies in an environ-
mentally-compatible manner  by providing the necessary environmental  data and
control technology. Investigations include analyses of the transport of energy-related
pollutants and their health and ecological effects; assessments of. and development of.
control technologies for energy systems; and integrated assessments of a wide range
of energy-related environmental issues
This document is available to the public through the National Technical Information
Service. Springfield. Virginia 22161

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                                              EPA-600/7-78-228
                                              November  1978
         REGULATORY WATER QUALITY MONITORING
              - A SYSTEMS PERSPECTIVE -
                          by
                   Robert C. Ward
  Agricultural and Chemical Engineering Department
              Colorado State University
            Fort Collins, Colorado  80523
           Contract Number CB-6-99-2530-A
                   Project Officer
                  Donald B. Gilmore
Monitoring Systems Research and Development Division
  Environmental Monitoring and Support Laboratory
               Las Vegas, Nevada  89114
        U.S. ENVIRONMENTAL PROTECTION AGENCY
         OFFICE OF RESEARCH AND DEVELOPMENT
   ENVIRONMENTAL MONITORING AND SUPPORT LABORATORY
              LAS VEGAS, NEVADA  89114

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                                DISCLAIMER
     This report has been reviewed by the Environmental Monitoring and Sup-
port Laboratory-Las Vegas, U.S.  Environmental Protection Agency,  and approved
for publication.  Approval does  not signify that the contents necessarily
reflect the views and policies of the U.S. Environmental Protection Agency,
nor does mention of trade names  or commercial products constitute endorsement
or recommendation for use.
                                     ii

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                                 FOREWORD
     Protection of the environment requires effective regulatory actions
which are based on sound technical and scientific information.  This infor-
mation must include the quantitative description and linking of pollutant
sources, transport mechanisms, interactions, and resulting effects on man
and his environment.  Because of the complexities involved, assessment of
specific pollutants in the environment requires a total systems approach
which transcends the media of 'air, water, and land.  The Environmental
Monitoring and Support Laboratory-Las Vegas contributes to the formation and
enhancement of a sound monitoring data base for exposure assessment through
programs designed to:


                  develop and optimize systems and strategies for.
                  monitoring pollutants and their impact on the
                  environment

                  demonstrate new monitoring systems and tech-
                  nologies by applying them to fulfill special
                  monitoring needs of the Agency's operating
                  programs

     This report covers a systems approach to regulatory water quality
monitoring and is intended to assist the monitoring systems manager to more
efficiently distribute resources between sampling sites and laboratory
resources to achieve better data distribution at a lesser cost.  For further
Information contact the Monitoring Systems Research and Development Division
at this Laboratory.
                             George B.' Morgan
                                 Director
              Environmental Monitoring and Support Laboratory
                                 Las Vegas
                                    ill

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                                   PREFACE


     Any attempt to evaluate, Improve or "optimize" a regulatory water
quality monitoring network should begin with the question, "Why do we want to
monitor?".  A review of the monitoring literature will very quickly reveal
that this question has not been adequately addressed.  Instead, we answer
questions such as, "How do I collect a water quality sample?"; "How do I
determine the amount of mercury in a sample?"; or "How do I handle data?".
We concentrate almost exclusively on determining how to monitor or how to
collect data—very rarely do we examine why we monitor or how we are to
utilize data and information in regulatory water quality management.  As a
result of this unbalanced situation, we are very good at collecting data but
very poor at using data or the information they yield.     A review of why
this has been the case indicates that rarely has the regulatory monitoring
system been viewed as a total system—from sample collection through infor-
mation utilization for water quality management decision-making.  In addition,
the purposes of monitoring have been expanded in recent years which further
complicates the situation.

     As an initial step toward developing a more systematic, thorough, and
balanced approach to regulatory monitoring, an overall systems perspective
has been developed.  The systems view of regulatory monitoring examines the
monitoring purposes and monitoring activities (including data collection and
utilization) and develops a monitoring system matrix.  Such a matrix places
past, present and future efforts at improving regulatory monitoring in proper
perspective.
                                      iv

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                                  CONTENTS
Forword	    ill
Preface	     iv
Acknowledgements  	     vi
Introduction  	      1
Conclusions 	      2
Recommendations 	      3
Monitoring Purposes 	      4
Monitoring Activities 	      8
Monitoring System Matrix  	     17
Summary	     20
References	     21
                                   FIGURES
Number

  1   The monitoring system based on the operational activities
      involved in the flow of information through a monitoring
      program	     14

  2   Monitoring system matrix  	     18

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                              ACKNOWLEDGEMENTS
     The author wishes to acknowledge the assistance of a number of individ-
uals and organizations in the development of this report.

     In addition to the financial support provided by the U.S. Environmental
Protection Agency (EPA), the support of the Colorado State University in
granting the author a sabbatical leave is gratefully acknowledged.
Mr. Knud S. Nielsen of the Water Quality Institute in Horsho1m, Denmark, and
Mr. Mogens Bundgaard-Nielsen of the Danish Environmental Protection Agency
contributed much to the author's thoughts on regulatory water quality moni-
toring .
                                     vi

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                                INTRODUCTION
      Regulatory water quality monitoring is that monitoring performed by
government agencies for the direct support of their water quality management
efforts within the political jurisdiction of the governmental body.  As the
public demand for a cleaner environment has intensified, the governmental
bodies have reacted with more comprehensive laws.  This, in turn, has resulted
in much more comprehensive regulatory water quality management programs.  The
monitoring systems that support this increasingly comprehensive management
are becoming more complex both in terms of the purposes for monitoring and
the activities involved in monitoring.

      As monitoring purposes are expanded and new monitoring methodologies
are developed, it is difficult to retain a clear perspective of the total
monitoring system.  In integrating the new purposes and activities into the
existing monitoring system, an overall perspective of the total system must
be maintained.

      The purpose of this report is to describe and analyze the evolving
regulatory monitoring system as it exists today and to develop an overall
perspective of the total system.  This involves a review of the regulatory
monitoring purposes that have been identified over the past few years; a
categorization and delineation of the monitoring activities associated with
regulatory monitoring; and development of a regulatory monitoring system
matrix which provides an overall perspective of the interaction between
monitoring purposes and activities.

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                                 CONCLUSIONS
     1.  A general definition of the regulatory water quality monitoring
system has been developed.

     2.  The definition provides a basis for more realistic management of the
total regulatory monitoring system, including all the purposes and activities
of such monitoring.

     3.  Water quality management strategies need to be tied more closely to
monitoring strategies in the context of a total regulatory monitoring system.

     4.  The role of data utilization within a regulatory water quality
monitoring system needs to be quantified.

     5.  In any attempt to develop regulatory water quality monitoring
evaluation and/or certification procedures, the interaction of the purposes
and activities Involved in such monitoring must be considered.

     6.  The impact of new regulatory water quality management goals on
regulatory monitoring should be carefully evaluated.

     7.  Before they are incorporated Into an existing regulatory water
quality monitoring system, new monitoring techniques and procedures should
be carefully evaluated with respect to their effect on monitoring and manage-
ment strategies.

     8.  The system view of regulatory monitoring developed in this report is
based upon a subjective classification of monitoring purposes and activities.
It should be considered a first cut at providing the basis upon which future
attempts can be made for "optimizing" the regulatory water quality monitoring
system.

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                               RECOMMENDATIONS
     As a means of further quantifying the regulatory water quality moni-
toring system, it is recommended that a regulatory water quality monitoring
strategy be developed.  The strategy should quantitatively spell out how
monitoring purposes and monitoring activities can be integrated to form a
total monitoring system.  The Integration of monitoring purposes and
activities must include the development of guidelines for the design,
operation and maintenance of all aspects of the system.

     Development of a regulatory water quality monitoring strategy must be
matched to the strategies employed by water quality management in using
monitoring data for making decisions.  This will require a thorough exam-
ination of data utilization within regulatory water quality management prior
to development of monitoring strategies.

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                            MONITORING PURPOSES
     The need to monitor water quality for regulatory purposes is stated in
most laws that establish water quality management programs.  As new laws are
passed dealing with additional aspects of water pollution or new approaches
to water quality management, the purpose of regulatory monitoring is expanded
to supply data and information on the additional aspects or for the new
management approaches.

     Within these legal classifications of monitoring purposes which, in
general, relate to the "location" of the water (e.g., surface water, ground-
water, etc.) there is a classification of regulatory monitoring purposes that
stems from the need to obtain trends (means) in water quality for certain
management functions (e.g., planning) and the need to obtain extremes in
water quality for other functions (e.g., enforcement of water quality
standards).

LEGAL CLASSIFICATION

     A review of the evolution of regulatory monitoring reveals the continuing
Federal attempt (through laws and studies) to more directly relate the purpose
of monitoring to management goals.  Passage of the Federal Water Quality Act
of 1965 (P.L. 89-234) resulted in the first organized and systematic approach
to water quality monitoring by newly created or reorganized State and local
agencies across the United States.  P.L. 89-234 established stream standards
as the basis of water quality management; thus the monitoring that resulted
was geared to instream conditions.

     The stream standards resulting from P.L. 89-234 were established as
levels of quality to be maintained.  They did not reflect the fact that a statis-
tical sampling program would be the source of information regarding compliance.
This led to confusion as  to the exact role of a monitoring program's input to
management's decision-making process.  In this particular case, monitoring was
generally initiated to meet the legal requirements of the law rather than for
clearly defined management decision-making purposes—a clearly defined data
utilization strategy was missing.

     Passage of the Federal Water Pollution Control Act Amendments of 1972
(P.L. 92-500) shifted emphasis of regulatory water quality management from
strictly stream standards to a combined stream and effluent standards basis.
With such a change came the need for the agencies to monitor effluents as a
means of verifying self-monitoring data reported to the Environmental Protec-
tion Agency (EPA).  After a number of years of collecting background data on
effluents, effluent standards based on historical records are beginning to
be written in statistical terms that more clearly define the relationship

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 between effluent monitoring (means and/or extremes)  and regulatory water
 quality management decision-making.


     Passage of the Safe Drinking Water Act of 1974  (P.L. 93-523) has drawn
attention to the need to monitor groundwater quality and, in many cases, is
pressuring agencies to Initiate groundwater monitoring for regulatory water
quality management purposes.

     These three laws have established the need for regulatory monitoring pro-
grams to routinely monitor water quality  in three general "locations"—
surface water, groundwater and effluents.  Each of the different locations
requires a monitoring operation (or system) geared to its own specific
characteristics.  For example, the ready  access of surface water is contrasted
with the need for a well to access groundwater; the rapidly changing surface-
water quality is contrasted with the relatively slowly occurring changes in
groundwater quality; the self-monitoring  requirements of effluent discharge
permits require that effluent monitoring  be more of a verification effort.


     The above routine monitoring operations—routine in the sense that they
have no designated termination date—are  complemented, in most management
agencies, by another type of monitoring referred to here as special surveys.
Special surveys are defined as monitoring efforts which have a designed
termination date.  The purpose and  forms  of special surveys are extremely
varied, as is  the manner in which  they are used in an overall monitoring
strategy.

     In an effort to more clearly define  the use of special surveys and to
better Identify their use with water quality management goals, the EPA's
Standing Work Group on Water Monitoring (1977) issued a report describing
a basic water monitoring program.  The proposed program would shift the
emphasis on surface water and effluent monitoring by management agencies
"from a fixed-station, single discharge approach to an intensive survey
approach."  This shifting of emphasis is  consistent with the recognition
over the past few years that the routine  high frequency sampling needed to
support an active enforcement of standards is very costly and often beyond
the resources of the management agencies.

MEANS VERSUS EXTREMES

     As water quality standards were initially written  they were absolute,
and enforcement action took place when the standard was violated.  To deter-
mine if a standard was violated required  data with very high sampling
frequencies—the extremes in water  quality were sought.  The means  (averages)
of water quality were used to detect trends in water quality over time and
distance.

     The need for high sampling frequencies for effective enforcement of
stream standards when combined with the limited resources available, created
problems in regulatory water quality monitoring.  These problems led the EPA

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to  fund several studies on the design of cost-effective monitoring systems
for surveillance purposes (Beckers _et al.,  1972, and Beckers and Chamberlain,
1974).

     These studies and others (Sherwani and Moreau, 1975, and Montgomery and
Hart,  1974) revealed the extremely intense monitoring effort needed to
obtain, in a routine manner, adequate information on extremes in water
quality.  Realizing that routine acquisition of data on extremes
is  impractical,  there is a tendency for agencies to rely upon effluent
monitoring data and special surveys for supporting enforcement actions.  The
special survey also helps in dealing with enforcement problems associated
with nonpoint sources.

     This shift in monitoring emphasis is reducing the routine monitoring
portion of the monitoring system and augmenting the effort put into special
surveys.  By having the routine monitoring seek only means, the design of
the network can be closely geared to the precision and confidence sought by
the management agencies' decision-makers.

SUMMARY OF MONITORING PURPOSES

     To summarize the above review of regulatory monitoring purposes, the
purposes are categorized and listed as follows:

                             ROUTINE MONITORING

                                Surface Water
                                    Means
                                  Extremes
                                 Groundwater
                                    Means
                                  Extremes
                            Effluent Verification
                               SPECIAL SURVEY

                                  Scheduled
                                Multipurpose
                               Single-purpose
                                 Unscheduled
                                Multipurpose
                               Single-purpose

     The categories of monitoring purposes include most of the purposes of an
agency.  Even though many agencies do not routinely measure surface water
extremes, some do have automatic monitoring networks that supply data on
extremes.  Routine monitoring of groundwater is little known relative to the
use of such data for regulatory water quality management purposes.  Effluent
verification monitoring, though a small portion of the total monitoring
system, validates a much larger source of data used for enforcement purposes,
I.e., the self-monitoring data reported by permit holders.

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     Routine monitoring is categorized around the locations of the water due
to the distinctive differences in the monitoring systems established for each
type of water.  Special surveys could likewise be categorized; however, as
noted by the National Water Monitoring Panel (1975), special surveys bridge
the gap between data bases generated by effluent monitoring and fixed-station
monitoring and provide a definitive basis for understanding and describing
the mechanisms, processes and interactions (surface and groundwater) that
affect water quality.

     Since special surveys are not routine, this operational aspect of their
purposes serves as an ideal basis for categorization.  Surveys that are
scheduled in advance often meet planning and enforcement goals.  Surveys that
must take place on the spur of the moment are often exclusively enforcement
oriented, caused by a pollution event.  Since the specific purpose of a
survey can vary, a further categorization can be distinguished by noting
whether a survey is multipurpose or single-purpose.

      Special  surveys may be  scheduled as  one-time  efforts  or  as a  series  of
 surveys.  The Standing Work  Group  on Water Monitoring  (1977)  recommended  that
 special  surveys be  scheduled "at least once within 5 years on every river,
 lake,  estuary, bay  or aquifer where waste loads are allocated or adverse
 water quality conditions have either been identified or are considered prob-
 able."  Unscheduled surveys  can occur at  any  time  and  Involve any  number  of
 different situations.  The National Water Monitoring Panel (1975)  noted the
 need to  plan  for  unscheduled events by allocating  resources to special sur-
 veys that will take place  due to these unscheduled events. Such unscheduled
 surveys  must  have a highly flexible mode  of  operation  as compared  to a
 scheduled survey.

     A scheduled multipurpose survey has been defined as a basin status
survey by the  National Water Monitoring Panel (1975).  Such surveys are often
conducted to assess the total water quality picture of a basin.  A scheduled
single-purpose survey is oriented toward a more specific objective:  load
allocations, nonpoint sources of pollution, etc.  Unscheduled multipurpose
surveys deal with pollution situations where the cause and effects are poorly
defined, while an unscheduled single-purpose survey deals with a more  clearly
defined pollution situation.  With the latter survey, the purpose may be only
to obtain evidence for enforcement action.

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                            MONITORING ACTIVITIES
     Monitoring purposes represent one dimension of the regulatory monitoring
system.  Another dimension is that associated with the operational activities
involved in the acquisition and utilization of data.  These activities begin
with the collection of samples and end with the data being used to make regu-
latory management decisions.  In between are a large number of activities
associated with the processing of samples and data, analysis of data,
reporting of the resulting information, etc.

     There are many ways that the monitoring activities could be categorized.
The approach chosen here is to broadly divide the activities into data acqui-
sition and data utilization.  The division is chosen to Indicate that both
major groups of activities are equally important to the effectiveness of a
total monitoring system.  In the past, most research and operational efforts
have been placed in the data acquisition area.  This has resulted in systems
more oriented toward acquiring data than to utilizing the data.  This
analysis of monitoring activities will treat both data collection and data
utilization equally.

DATA ACQUISITION

     Operationally, on a routine basis, data acquisition consists of sample
collection and laboratory analysis.  However, prior to sample collection,
the sampling locations, frequency of sampling, parameters measured, etc.,
must be determined by network design.  Thus when defined in categories, data
acquisition consists of, in order, network design, sample collection, and
laboratory analysis.

     Network design has received considerable research attention since the
early 1970's.  Ward (1973) and Montgomery and Hart (1974) discuss the design
of stream monitoring networks which detect means in quality; as noted earlier,
Beckers and Chamberlain (1974) examine the design of stream monitoring net-
works which measure extremes; Todd et^ a±. (1976) discuss the design of
groundwater monitoring networks; Cohen et al. (1975) present a design
procedure for effluent monitoring; and Kittrell (1969) discusses the factors
to consider in the design of a special stream survey.  Sherwani and Moreau
(1975) discuss network design for a range of monitoring purposes.

     A review of the above and other literature on the subject reveals the
need for extensive knowledge of an area if station locations and parameters
measured are to be dealt with In a quantitative manner.  Obtaining such
extensive information is often too costly, thus precluding use of the more
sophisticated design methodologies.  The network design, in such cases, is
often placed in the hands of personnel who are quite familiar with the water

                                      8

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quality situation.  There are a number of basic statistical procedures which
can assist in  the determination of  sampling  frequencies if some information
is available on past variances in water quality (Ward et_ al_., 1976).


     The sample collection activity involves taking field measurements,
collecting the sanple at the most representative point, using proper methods
of collecting and preserving the samples for transportation to the laboratory.
The exact procedures to use depend upon the type of water being sampled, the
parameters to be measured, the types of analyses used in the laboratory, etc.
Huibregtse and Moser (1976) present guidelines for sampling and sample
preservation for a number of different situations and cite numerous refer-
ences on the subject.

     Laboratory analysis is a complex activity in that it involves the analy-
sis for numerous water quality parameters with numerous alternative proce-
dures.  In addition, the operational procedures (handling and flow of
samples) in the laboratory, the quality control and the recording of the data
are major laboratory analysis activities.  Although quality control has
received more attention in the laboratory, it is equally important in all
monitoring system activities.

     Considerable effort has been put into the development of standard
laboratory analysis procedures (American Public Health ^'.ssociation, 1976;
Federal Interagency Work Group on Designation of Standards for Water Data
Acquisition, 1972; and the U.S. Environmental Protection Agency, 1974).  All
aspects of laboratory analysis have been examined recently by Tracor Jitco,
Inc. (1976) and the EPA's Water Supply Quality Assurance Work Group (1976)
in the development of procedures for evaluating and certifying laboratories.

     Assimilating the large amount of information on data acquisition and de-
signing a data acquisition system are not easy tasks;  however, an even
larger problem in establishing a sound data acquisition portion of a total
monitoring system is the lack of a  corresponding level of information on data
utilization.  It is difficult to design a well balanced, smoothly operating
monitoring system if there is any part of the system that is not well defined.

Data Utilization

     The relatively small number of studies in the area of data utilization
for regulatory water quality management purposes is probably indicative of
the difficulty in dealing with the  subjective nature of the decision-making
involved.  During the data utilization portion of a monitoring program,
objective pieces of data are converted into information which is then used in
a rather subjective manner to assist decision-making.

     The conversion of data into information involves basically two
categories of activities.  First, the data must be stored in such a manner
that they are properly screened and verified and are easy to retrieve and
manipulate.  Second, data analysis  technique must be chosen such that the

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 information generated:  1) matches the ability of the data to yield such
 information with confidence, and 2) matches the expectations of the decision-
 makers.

      Beyond the  conversion of  data to  information, data  utilization includes
 a  category  of  activities which ensure  that  the  information is  utilized  in  the
 manner  for  which the entire monitoring system was designed and by which it
 justifies its  existence.   Thus,  data utilization consists  of three  major
 categories  of activities:  1) data handling,  2) data analysis, and 3)  infor-
 mation  utilization.

 Data  Handling

      The conversion of data into information begins with data  handling.  The
 initial step is  to acquire  (make arrangements to receive)  all  the data  that
 are available  and relevant  to  the water quality being managed  by the agency.
 Data  generated outside the  agency  (e.g., EPA, United States Geological  Survey
 (USGS), local  agencies, and effluent permittees) would enter the monitoring
 system  at this point.

      Besides data on water  quality, there are many other types of information
 that  are frequently needed  and used in water quality management.  The Joint
 Committee on Water Quality  Management Data  (1967) established  ten categories
 (e.g.,  data on the status of compliance with regulations,  data on the type
 and design  of  wastewater treatment plants, data on the personnel and fiscal
 resources used to conduct water  quality management, etc.).

      Once data are received, they are evaluated and verified for accuracy.
 This  is often  done in the process of putting the data into a storage system,
 especially  if  the data are  to be stored on a computer.  The Joint Committee
 on Water Quality Management Data (1967) discusses the alternatives available
 for storing and retrieving  data.

      The increasing availability and efficiency of computers with respect  to
 storage and retrieval of data are attracting the attention of  many agencies.
 The Commonwealth of Pennsylvania (1974) is using a modified form of  the Joint
 Committee on Water Quality Management Data's (1967) list of categories to
 develop a complete computer-based water quality management information
handling system.

     Baseman et al. (1975)  describe the basic components needed in a compu-
 terized data handling system for water quality management.  They list three
 levels of data use:  (1) listing, (2) summary and report, and  (3) mathe-
matical models for sophisticated decision-making.

     Michigan has also developed a computer-based data handling system;
however, it deals only with water quality data.  It is tied closely  to
STORET, the EPA's computer system for storing and retrieving data.   The
Michigan system is described by Guenther et al. (1973).
                                      10

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     The EPA's STORE! system is available to all State and local agencies for
storage and retrieval of their water quality data and its use is expanding.
Having many agencies use a common system has many advantages from an overall
efficiency point-of-view.

     Beyond having valuable and accurate data stored in a readily available
system, data handling includes the means of reporting and disseminating raw
data to other agencies and organizations.  The purposes of such reporting and
dissemination of raw data is to assist other agencies and organizations in
their data acquisition efforts, thereby increasing the value and utilization
of all data collected through reduction in the duplication of acquisition
efforts.

Data Analysis

     Data handling and data analysis are closely related since many data
analyses require the rapid manipulation of large amounts of data.  Even with
the data stored in an accommodating system, the multiplicity of parameters
which determine water "quality", the ever-changing nature of water, and the
broad scale of management combine to create a formidable obstacle to obtaining
precise information from the data during this analysis activity.

     There are a number of broad categories of techniques which can be used
to analyze water quality data.  The more general techniques (basic statistics,
indices, etc.) are most often used for a broad-scale (time and/or space)
analysis of water quality conditions.  When a specific water quality problem
is identified (one parameter, one source, one river, etc.), the more specific
types of data analysis techniques (time series analysis, modeling, etc.), are
more applicable as normally more data are taken to solve the problem (through
special or intensive surveys).

     The particular type of analysis used will depend upon many factors
besides the data handling procedures.  The type of data (often low sampling
frequency) collected by many agencies restricts the analysis that can be used
and, consequently, the level of information achieved by the monitoring system.
The form of the decision-making body (layman or professional) may influence
the data analysis technique as well as the type of problems being encountered.
The statistical training of the personnel and the facilities available for
performing the analysis will influence the analysis as well as the purpose of
monitoring.

     Literature describing the types of data analysis applicable to regula-
tory water quality monitoring data is rather limited.  There are many
studies that describe the use of statistics with high frequency water quality
data and special survey data, but few that deal specifically with data
collected for regulatory purposes—relatively low frequency data.

     To illustrate the type of literature available, a few publications will
be cited.  Cochran (1963) in a sampling textbook describes the range of
basic statistics that can be used to analyze data.  Brown et al. (1970) and
Landwehr and Deininger (1976) describe water quality indices.   Samson et al.
(1970) in a textbook describe the basics of statistical quality control,

                                      11

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while Deininger (1971) relates quality control concepts to water quality data.
Wastier (1969) discusses techniques available for analyzing the time series
aspects of water quality data.  Thomann (1972) reviews the available
approach for water quality modeling while Gross (1975) presents a bibliography
of water quality modeling efforts.

     Each of the categories of data analysis techniques has many variations
depending upon the characteristics of the data and the type of information
sought.  As a result, design of a total monitoring system requires a clear
definition of the information sought which must, in turn, be balanced against
the type of data available.  The careful balancing of the information expec-
tations and available data around the analysis techniques is an area needing
more attention, particularly, with respect to regulatory water quality
monitoring.

Information Utilization

     Information utilization is the activity that takes the information from
the data analysis activity and ensures that it is utilized.  This involves a
set of quantitative information distribution steps followed by a subjective
evaluation of the information's usefulness.  The latter subactivity is the
beginning of a feedback loop in a regulatory monitoring system that provides
for the adjustments needed to keep the system relevant.

     Distribution of information involves determining where the points of use
are, what types and quantities of information are needed at each point, and
with wVat frequency the Information is needed.  In addition, the best means
of injecting (report, oral presentation, action sheets, etc.) the information
into its point-of-use needs to be identified.

     In utilizing information for decision-making in a regulatory water
quality management program, the points of decision are at various levels.  At
the lower levels, operational decisions are made as to whether a water
quality change warrants investigation.  Such decision can be based upon a
given deviation from past trends.  For example, three samples out of the past
four being more than two standard deviations away from the historical mean
could necessitate an investigation.  Different types of investigative actions
could be matched to different levels of deviation from expected values.

     Another type or level of decision-making occurs at the program level
(establishing management strategy within the agency).  Here management re-
sources are devoted to different programs depending upon the problems
involved and the effectiveness of different programs to handle a problem.
The monitoring information assists in Identifying problems and priority rank-
ing them. Of ten , compressing the information into an index is useful at this
stage, not only for comparing problems, but for comparing the effectiveness
of different programs for handling problems.

     The planning of general policy or decision-making policy occurs at a
point  far removed from the monitoring operations.  If data and information
are to play a role in policy making, they must be reported in a format that


                                      12

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fits the occasion.  This often requires considerable ingenuity on the part of
monitoring personnel in not only the analysis and compression of the data
but, also,    the reporting and presentation of the data and information.

     At all levels of decision-making within water quality management where
monitoring data are  used, there are different philosophies or approaches
which can be used to direct the manner in which decisions are made.  The
approach to decision-making used by an agency will affect the monitoring
system.  For example, in solving environmental problems, Lindblom (1973)
suggests two broad management or decision-making approaches:  (1) the
traditional, conventionally scientific method and (2) a much more highly
selective, incremental, tactically focused method.  He argues that by using
the second approach, the actions of an agency are more precisely defined,
making it easier to accomplish the goals.  The first approach results in
too broad a definition of goals, poorly defined actions and, in the end,
no true or accurate measure of whether the goals were accomplished.

     House (1973), on the other hand, states:

     "The instinct is for each Federal, State or local agency to treat
     individual environmental problems as separate entities and to
     concentrate on short-range crises rather than long-range trends.  This
     approach is inefficient, not only because of its tendency to duplicate
     efforts but, also, because it ignores the fact that pollution abatement
     problems are long term, intertwined and mutually dependent."

     Each management agency establishes its own approach to decision-making
either informally or formally.  Whichever is chosen, the monitoring strategy
as a whole, and the information utilization activity in particular, must
reflect the information needs.

     Beyond establishing quantitative information utilization procedures, the
actual use of the information needs to be evaluated as a means of ensuring
that the needed information is actually being produced by the monitoring
system.  Evaluating the information's usefulness will  often consist of only
a subjective appraisal by the decision-maker.  Such evaluations should be
made, however, and they should initiate a loop that encompasses the entire
monitoring system.

SUMMARY OF MONITORING ACTIVITIES

     In the data acquisition  and  utilization discussions, six categories of
activities have been Identified.  These six categories are shown in their
operational setting in Figure 1.  Network design, as noted earlier, is not a
routine operation, but is vital to the effective operation of the system.
The five routine operational categories follow the flow of information
through the monitoring system and tie the water quality being managed to the
decisions made with respect to management.  The monitored changes are the
feedback loop in the system.
                                      13

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                          MONITORING ACTIVITIES
               NETWORK
               DESIGN
                              WATER QUALITY
                            SAMPLE COLLECTION
                           LABORATORY ANALYSIS
                              DATA HANDLING
                              DATA ANALYSIS
                         INFORMATION UTILIZATION
                             DECISION MAKING
    Figure 1.  The monitoring system based on the operational
              activities involved in the flow of information
              through a monitoring program.

     The  six monitoring activity categories can be summarized in more of a
functional manner as has been discussed previously.   The number and diversity
of the activities in the following list illustrates the complexity of the
activity  dimension of regulatory water quality monitoring.

                            NETWORK DESIGN

                              1. Station Location
                              2. Parameter Selection
                              3. Sampling Frequency

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                               SAMPLE COLLECTION

                                 1.  Sampling  Technique
                                 2.  Field Measurements
                                 3.  Sample Preservation
                                 4.  Sampling  Point
                                 5.  Sample Transport

                               LABORATORY ANALYSIS

                                 1.  Analysis  Techniques
                                 2.  Operational Procedures
                                 3.  Quality Control
                                 4.  Data Recording

                               DATA HANDLING

                                 1.  Data Reception
                                    a.  Laboratory
                                    b.  Outside Sources
                                 2.  Screening and Verification
                                 3.  Storage and Retrieval
                                 4.  Reporting
                                 5.  Dissemination

                               DATA ANALYSIS

                                 1.  Basic Summary Statistics
                                 2.  Regression Analysis
                                 3.  Water Quality Indices
                                 4.  "Quality  Control" Interpretation
                                 5.  Time Series Analysis
                                 6.  Water Quality Models

                               INFORMATION UTILIZATION

                                 1.  Information Needs
                                 2.  Reporting Formats
                                 3.  Operational Procedures
                                 4.  Utilization Evaluation

     Managing such a system is becoming more  difficult as the complexity
grows.  Several studies in recent years have  attempted to evaluate the entire
monitoring activity dimension.   The National  Water Monitoring Panel (1975)
presents a discussion on what  a  model state monitoring program would contain,
while the Standing Work Group  on Water Monitoring (1977) presented an overall
monitoring strategy.  Schnider and Shapiro (1976) developed a procedure for
evaluating a monitoring program.

     In all three studies, the lack of information on data utilization, as
defined in this report, prevents a well-balanced approach to the total noni-
toring system.  The lack of information on data utilization, as noted earlier

                                      15

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steins mainly from a lack of emphasis in this area of monitoring, as compared
to the emphasis placed on data collection.  From a research point of view,
data are often considered a subjective factor in monitoring and at the
personal whim of the user.  From a regulatory standpoint, however, the
data collected by a management agency should be carefully related to its use.
                                       16

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                          MONITORING SYSTEM MATRIX


     Two dimensions of regulatory water quality monitoring systems have been
discussed:   (1) monitoring purposes and (2) monitoring activities.  These
dimensions are considered critical to gaining an overall perspective of the
monitoring system.

     If the  two dimensions are combined to form a monitoring system matrix,
the interaction of purposes and activities can be more easily visualized.  A
monitoring system matrix is presented in Figure 2.  The 5 major purposes of
monitoring in Figure 2 combine with the 6 major activities of monitoring to
create some  30 major combinations of monitoring purpose/activity that must be
designed to  fit into an overall system.  Knowing that the interaction of each
purpose/activity block with all the others occurs is one thing, but
identifying  (or quantifying) the interaction is another.

     From an overall monitoring system management viewpoint, such inter-
actions may best be dealt with from a common basis—basic resources of
money, personnel, etc.  Allocation of resources among the various monitoring
purposes establishes the agencies' monitoring and, consequently, management
strategy.  For example, assuming equal output is obtained from each purpose
for equal input of resources, an agency that allocated 60 percent of its
monitoring budget to special surveys would be emphasizing this type of
monitoring.  Continuing the example, a further breakdown may have 20 percent
for routine surface water monitoring, 15 percent for routine effluent
monitoring, 50 percent for scheduled surveys and 10 percent for unscheduled
surveys.  Such a percentage breakdown more clearly establishes an agency's
overall regulatory monitoring strategy relative to its purposes.

     The allocation of resources among the monitoring activities could like-
wise be divided.  In all probability, however, the percentage of a budget
allocated to routine surface-water sample collection would not be the same as
that allocated to routine effluent sample collection.  A higher portion of
effluent monitoring monies would be devoted to data utilization, since much
of the data has no or little acquisition cost to the agency.  Thus, each moni-
toring purpose would have its own percentage allocation to the monitoring
activities.

     If an allocation of resources to monitoring purposes and monitoring
activities is to take place with a clear understanding of the total monitoring
system, the system must be carefully defined.  The monitoring system matrix in
Figure 2 provides a generalized framework around which an agency can formulate
a definition of its particular monitoring system.  The framework,  by consid-
ering data utilization in more detail, provides a more thorough perspective of
a monitoring system than has generally been considered in the past.

                                      17

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— ^^^flonitoring Purposes
Monitoring Activities ' -~^_
Network Design
1. Station Location
2. Parameter Selection
3. Sampling Frequency
Sample Collection
1. Sampling Point
2. Field Measurements
3. Sampling Technique
4. Sample Preservation
5. Sample Transport
Laboratory Analysis
1. Analysis Techniques
2. Operational Procedures
3. Quality Control
4. Data Recording
D«ta Handling
1. Data Reception
a. Laboratory
b. Outside Sources
2. Screening and Verification
3. Storage and Retrieval
4. Reporting
5. Dissemination
Data Analysis
1. Basic Summary Statistics
2. Regression Analysis
3. Water Quality Indices
4. Quality Control Interpret..
5. Time Series Analysis
6. Water Quality Models
Information Utilization
I. Information Needs
2. Reporting Formats
3. Operational Procedures
4. Utilization Evaluation
Routine Monitoring
Surface






Ground






Effluent






Special Surveys
Scheduled






nscheduleH






Figure 2.  Monitoring System Matrix
                 18

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     Using the matrix as a basis for examining the balance of past research
efforts on monitoring systems design and operation, some general conclusions
can be drawn.  The first three activities have received considerably more
attention than the last three.  Within the last three activities, data
handling and analysis have received more attention than information utili-
zation, an area that has received almost no attention.

     Under purposes, surface water has historically received the most atten-
tion while effluent monitoring is currently receiving increasing attention as
the permit system mandated by P.L. 92-500 takes full effect.  Groundwater
monitoring, on a routine basis within  political boundaries, has received
little attention relative to the importance given it under P.L. 93-523.
Special surveys, until recently, have not received enough attention to
clarify their exact role.  Recent developments  (Standing Work Group on Water
Monitoring, 1977) may shift more emphasis to special surveys, thus providing
a basis for refinement in their purpose, design and operation.
                                      19

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                                   SUMMARY
     Regulatory water quality monitoring systems have been and still are
evolving very rapidly.  Each agency approaches the job of regulatory moni-
toring from a different angle, thereby making generalizations difficult.
However, from the national initiative in environmental control have come some
basic monitoring purposes which have been described.  In addition, there are
some basic categories of activities associated with monitoring.  A set of
activity categories has been defined and discussed.

     By combining the monitoring purposes and monitoring activities in a
matrix format, it is possible to gain a perspective of the total regulatory
water quality monitoring system.  Such a perspective is very helpful in
developing well-balanced monitoring programs and in identifying weak areas
needing additional research and/or support.
                                      20

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                                  REFERENCES
 1.   American Public Health Association.   1976.   Standard Methods for the
     Examination of Water and Waste Water.   Fourteenth Edition,  American Public
     Health Association, 1015 Eighteenth Street, N.W., Washington, D.C.   20036.

12)   Beckers, C. V., S.  G.  Chamberlain, and G.  P. Grinsrud.   1972.  Quanti-
     tative Methods for Preliminary Design of Water Quality  Surveillance
     Systems.  U.S. Environmental Protection Agency, Socioeconomic Environ-
     mental Studies Series Report No.  EPA-R5-72-001, November.

/13  Beckers, C. V., and S. G. Chamberlain.  1974.  Design of Cost-effective
     Water Quality Surveillance Systems.   U.S.  Environmental Protection  Agency,
     Socioeconomic Environmental Studies Series Report No. EPA-600/5-74-004,
     January.

 4.   Brown, R. M., N. I. McClelland, R. A.  Deininger and R.  G.  Tozer.  1970.
     A Water Quality Index - Do We Dare?  Proceedings of the National Symposium
     on Data and Instrumentation for Water Quality Management,  Madison,
     Wisconsin, July.

f§)l   Cochran, W. G.  1963.   Sampling Techniques.  John Wiley and Sons, Inc.,
     New York.

/&.   Cohen, A. I., Y. Bar-Shalom, W. Winkler and G. P. Grinsrud.  1975.   A
     Quantitative Method for Effluent Compliance Monitoring Resource Alloca-
     tion.  U.S. Environmental Protection Agency, Socioeconomic Environmental
     Studies Series Report No. EPA-600/5-75-015, September.

 7.   Commonwealth of Pennsylvania.  1974.  Demonstration of a State Water
     Quality Management Information System.  U.S. Environmental Protection
     Agency, Socioeconomic Environmental Studies Report No.  EPA-600/5-74-022,
     August.

 8.   Deininger, R. A.  1971.  Optimizing Automatic Water Quality Monitoring
     Programs.  Proceedings of the Specialty Conference on Automatic Water
     Quality Monitoring in Europe, March 29-April 2, 1971.  Technical Report
     No. 28, Department of Environmental and Water Resources Engineering,
     Vanderbilt University, pp. 363-389.

 9.   Federal Interagency Work Grouo on Designation of Standards for Water
     Data Acquisition.   1972.  Recommended Methods for Water-Data Acquisition.
     U.S. Department of the Interior,  Geological Survey, Office of Water
     Data Coordination,  December.
                                      21

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10.  Gross, A. J.  1975.  A Review of Statistical Procedures Used for Exami-
     nation of Water Data.  Publication No. 58, Completion Report FY-76-6,
     Water Resources Research Center, University of Massachusetts at Amherst,
     April.

11.  Guenther, G., D. Mincavage and F. Morley.  1973.  Michigan Water
     Resources Enforcement and Information System.  U.S. Environmental
     Protection Agency, Socioeconomic Environmental Studies Series Report
     No. EPA-R5-73-020, July.

12.  Haseman, W. D., A. Z. Lieberman and A. B. Whinston.  1975.  Water Quality
     Management and Information Systems.  Journal of the Hydraulics Division,
     ASCE, Vol. 101 (HY3):  pp. 477-493, March.

13.  House, P.  1973.  Decision-making for Environmental Quality.  In Managing
     the Environment, U.S. Environmental Protection Agency Report No. EPA-600/
     5-73-010, November.

14.  Huibregtse, K. R., and J. H.  Moser.  1976.  Handbook for Sampling and
     Sample Preservation of Water and Waste Water.  U.S. Environmental
     Protection Agency Report No.  EPA-600/4-76-049, September.

15.  Joint Committee on Water Quality Management Data.  1967.  Water Quality
     Management Data Systems Guide.  Conference of State Sanitary Engineers,
     Harrisburg, Pennsylvania, May.

16.  Kittrell, F. W.   1969.   A Practical Guide to Water Quality Studies of
     Streams.  Federal Water Pollution Control Administration Publication
     No. CWR-5, U.S.  Department of the Interior.

17.  Landwehr, J. M., and R. A. Deininger.  1976.   A Comparison of Several
     Water Quality Indexes.   Journal of the Water Pollution Control Feder-
     ation, Vol. 48(5): pp.  954-958, May.

18.  Lindblorn, C.  1973.  Incrementalism and Environmentalist!!.  In Managing
     the Environment, U.S. Environmental Protection Agency Report No. EPA-600/
     5-73-010, November.

     Montgomery, H. A. C., and I.  C. Hart.  1974.   The Design of Sampling
     Programs for Rivers and Effluents.  Journal of the Institute of Water
     Pollution Control, Vol. 33(1):  pp. 77-101.

20.  National Water Monitoring Panel.  1975.  Model State Water Monitoring
     Program.  U.S. Environmental Protection Agency Report No. EPA-440/9-74-
     002, June.

21.  Samson, C., P. Hart and C. Rubin.  1970.  Fundamentals of Statistical
     Quality Control.  Addison-Wesley.
                                     22

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22.  Sherwani, J. K., and D. H. Moreau.  1975.  Strategies for Water Quality
     Monitoring.  Report No. 107, Water Resources Research Institute of the
     University of North Carolina, 124 Riddick Bldg., North Carolina State
     University, Raleigh, NC, June.

23.  Schnider, R. W., and E. S. Shapiro,  1976.  Procedures for Evaluating
     Operations of Water Monitoring Networks.  U.S. Environmental Protection
     Agency Report No. EPA-600/4-76-050, September.

24.  Standing Work Group on Water Monitoring.  1977.  Basic Water Monitoring
     Program.  U.S. Environmental Protection Agency Report No. EPA-440/9-76-
     025.

25.  Thomann, R. V.   1972.  Systems Analysis and Water Quality Management.
     Environmental Research and Application, Inc.  New York.

26.  Todd, D. K., R. M. Tinlin, K. D. Schmidt and L. G. Everett.  1976.  Moni-
     toring Groundwater Quality:  Monitoring Methodology.  U.S. Environmental
     Protection Agency Report No. EPA-600/4-76-026, June.

27.  Tracer Jitco, Inc.  1976.  Procedure for the Evaluation of Environmental
     Monitoring Laboratories (Rough Draft).  Report Submitted to the U.S.
     Environmental Protection Agency as a Completion Report for Contract No.
     68-03-2171.

28.  U.S. Environmental Protection Agency.   1974.  Methods for Chemical
     Analysis of Water and Wastes.  EPA-625/6-74-003, Office of Technology
     Transfer, U.S. EPA, Washington, D.C.  20460.

29.  Ward, R. C.  1973.  Data Acquisition Systems in Water Quality Management.
     Environmental Protection Agency, Socioeconomic Environmental Studies
     Series Report No. EPA-R5-73-014, May.

30.  Ward, R. C. , K. S. Nielsen and M. Bundgaard-Nielsen.  1976.  Design of
     Monitoring Systems for Water Quality Management.  Contributions from the
     Water Quality Institute, Danish Academy of Technical Science, No. 3,
     Horsholm, Denmark, December.

31.  Wastler, T. A.   1969.  Spectral Analysis.  Application in Water Pollution
     Control.  Report No. CWT-3, U.S. Department of the Interior, Washington,
     D.C.

32.  Water Supply Quality Assurance Work Group (2nd Draft).  1976.  Criteria
     and Procedures for Certification of Water Supply Laboratories.  Moni-
     toring Technology Division, Office of Monitoring and Technical Support,
     U.S. Environmental Protection Agency, Washington, D.C., December.
                                     23

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                                    TECHNICAL REPORT DATA
                            (Pleat read Instructions on the revene before completing}
i. REPORT NO.
   EPA-600/7-78-228
                              2.
                                                             3. RECIPIENT'S ACCESSION NO.
4. TITLE AND SUBTITLE

   REGULATORY WATER QUALITY MONITORING - A SYSTEMS
   PERSPECTIVE
              5. REPORT DATE
                November 1978
              6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
   Robert  C.  Ward
                                                             I. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS

   Colorado State University
   Fort Collins,  Colorado  80523
              10. PROGRAM ELEMENT NO.

                 1NE624
              11. CONTRACT/GRANT NO.

                CB-6-99-2530-A
12. SPONSORING AGENCY NAME AND ADDRESS
   U.S. Environmental Protection  Agency-Las Vegas,  NV
   Office of  Research and Development
   Environmental Monitoring and Support Laboratory
   Las Vegas.  NV  89114        	        	
                                                             13. TYPE OF REPORT AND PERIOD COVERED
              14. SPONSORING AGENCY CODE

                EPA/600/07
IS. SUPPLEMENTARY NOTES
   For further information, contact Donald B. Gilmore, Project Officer (702) 736-2969,
   ext. 241,  in  Las Vegas, NV  	                               	
16. ABSTRACT
   The purpose  of this report  is  to describe and  analyze the evolving regulatory
   monitoring system as it exists today and to develop an overall  perspective of  the
   total system.   This Involves a review of regulatory monitoring  purposes that have
   been identified over the past  few years; categorizing and delineating the monitoring
   activities associated with  regulatory monitoring;  and development of a regulatory
   monitoring system matrix which provides an overall perspective  of the interaction
   between monitoring purposes and activities.
17.
                                KEY WORDS AND DOCUMENT ANALYSIS
                  DESCRIPTORS
b. IDENTIFIERS/OPEN ENDED TERMS  C. COS AT I Field/Group
   Design criteria
    Water monitoring
14A
18. DISTRIBUTION STATEMENT
   RELEASE TO PUBLIC
                                               19. SECURITY CLASS (TM* Report)
                                                   UNCLASSIFIED
                            21. NO. OF PAGES
                                 32
                                               20. SECURITY CLASS (Thltpage)
                                                   UNCLASSIFIED
                            22. PRICE

                                 A03
EPA form 2220-1 (R»v. 4-77)    PREVIOUS EDITION i* OBSOLETE
                                                                             ft U.S. 6PO:1V79-6M-1M/20M

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