United States Office ot Water IWH 5561 EPA440/2-85-801 Environmental Protection Washington DC 20460 September 1985 Agenc'' FINAL A Guide to the Office of Water Accountability System and Mid-Year Evaluations Fiscal Year 1986 ------- A GUIDE TO THE OFFICE OF WATER ACCOUNTABILITY SYSTEM AND MID-YEAR EVALUATIONS Fiscal Year 1986 Office of water U.S.- Environmental Protection Agency Washington, D.C. 20460 ------- TABLE OF CONTENTS Page I. INTRODUCTION 1 II. THE OFFICE OF WATER ACCOUNTABILITY SYSTEM 2 A. Appendix A: The Measures 2 B. Appendix B: The Definitions 4 III. THE OFFICE OF WATER EVALUATION SYSTEM 5 A. Prenegotiated Comiitments and Quarterly Reporting • 5 B. Mid-year Evaluations 6 1. Advance Preparation 6 2. On-site Evaluations 7 3. Evaluation Follow-up 9 C. Other Office of Water Information Collection Activities 9 D. Timeline for Activities Related to the FY 1986 Agency Operating Guidance 11 APPENDIX A — Measures Municipal Pollution Control A-l - A-10 Water Quality Enforcement & Permitting A-ll - A-47 Marine and Estuarine Protection A-48 - A-55 Underground Injection Control Program A-56 - A-61 Public Water Systems Supervision A-62 - A-65 Groundwater Protection A-66 - A-68 Water Quality Standards, Planning and Assessments A-69 - A-78 APPENDIX B — Definitions Municipal Pollution Control B-l - B-12 Water Quality Enforcement & Permitting B-13 - B-29 Underground Injection Control Program B-30 - B-32 Public Water Systems Supervision B-33 - B-34 Water Quality Standards, Planning and Assessments B-35 - B-36 ------- I. INTRODUCTION In FY 1986, the Office of Water will continue to conduct formal, coordinated evaluations of Regional water programs. The purpose of these reviews is to evaluate Regional performance in achieving National program objectives for the year, and to help ensure National consistency in imple- mentation of Federal laws and regulations. [This guide contains the accountability measures that the Office of Water will use to monitor Regional performance, and describes the process that the Office of Water will use to evaluate Regional water programs in FY 1986J The guide should be used in conjunction with the Ajency's FY 1986 Operating Guidance, which sets forth the National objectives for water programs. _Page 1 ------- II. THE OFFICE OF WATER ACCOUNTABILITY SYSTEM The Office of Water Accountability System consists of a set of qualita- tive and quantitative measures that provide the basis for evaluating Regional Office performance against National program objectives. The measures in the system include all measures included in the Strategic Planning and Management System as well as additional qualitative and quantative measures which are needed to fully evaluate performance against the Office of Water's FY 1986 national program objectives. In general, the measures from the Strategic Planning and Management System relate to the Agency's Priority List and should be considered the highest priority program activities. The structure of the FY 1986 Office of Water Accountability System remains essentially the same as the FY 1985 system. The following is a brief description of the accountability system, which is presented fully in Appendix A and B. A. Appendix A; The Measures Appendix A contains the Office of Water Accountability System, which is structured as a series of charts that contain the following categories of information: National Program Objectives; These are the Office of Water's major policy objectives for FY 1986.The objectives are action items as stated in the Agency Operating Guidance for FY 1986-1987. The page number in parentheses following each objective refers to the page in the Operating Guidance where the action item is listed. Activity Areas; These are the high priority activities that Regions and States should undertake in order to carry out National program objectives. The Office of Water does not expect the Regions to address every area. Rather, each Region should identify its key program areas, and should focus on those activities that are relevant to its particular circumstances. At the time of the mid-year evaluations, however, the Region will be asked to identify activity area(s) that are not considered to be priorities and to explain how the Region arrived at its decision. __Page 2 ------- Section II Office of Water Accountability System Office of Water Evaluation Guide Reporting Measures; The reporting measures are designed to generate the key data and information that the Office of Water needs to evaluate Regional progress towards achieving National program objectives. There are two kinds of reporting measures: 0 Qualitative measures are the specific questions that Regions are expected to address during the Office of Water mid-year evaluations. The measures relate primarily to program accomplishments and effec- tiveness, and generally do not involve prenegotiated commitments. 0 Quantitative measures provide the kinds of information that the Office of Water needs for program management and reporting purposes and for responding to Congressional inquiries. These measures include all measures included in the Strategic Planning and Management System (SPMS), as well as some unique to the Office of Water system. Many of these measures involve prenegotiated commitments with the Regions (see Section below). In SPMS/Commitment; This column 1) designates those measures that appear in the FY 1986 Strategic Planning and Management System and 2) identifies whether or not the measure involves a prenegotiated commitment between the Office of Water and the Regions. This column relates largely to quantitative measures; the principal exception is the qualitative measures related to developing Regional or State strategies by specific deadlines. Reporting Frequency; This column conveys the planned reporting schedule for specific prenegotiated commitments. Source of Data: This final column identifies the means by which the Office of Water wilT secure the required information from the Regions. Where there are existing data systems such as the Grants Information Control System (GIGS), the Permits Compliance System (PCS), and the Federal Reporting Data System (FRDS), the information will usually be drawn from that source. Page 3 ------- Section II Office of Water Accountability System Office of Water Evaluation Guide The measures in the accountability system will provide the Office of Water with much of the information necessary to monitor Regional performance in water programs. The accountability system is not intended to provide all the information that the Office of Water needs during the year (see Section III)r nor to limit the kinds of information that Regions may need for overview of State water programs. As part of its overview function, the Region is expected to gather the basic information to prepare its midyear self-evaluation and to participate effectively in the Office of Water mid-year evaluations. Regions may, however, seek additional information from States through program audits or other activities, and may choose to evaluate State management of water program activities that are not covered in the Office of Vfater guidance or accountability system. B. Appendix B; The Definitions Appendix B contains detailed, technical information that more clearly defines some of the quantitative measures contained in Appendix A. These definitions explain the precise manner in which the Region is expected to report the required information to the Office of Water. For seme measures, it also establishes a specific level of performance that each Region is expected to achieve during the quarter/fiscal year, and explains how the Office of Water plans to evaluate performance in these areas. Page 4 ------- III. THE OFFICE OF WATER EVALUATION SYSTEM The Office of Water Accountability System contains both quantitative and qualitative measures. While the Office of Water plans to use both types of measures to monitor Regional performance during the year, Regions will be asked to provide the information in two different ways: quarterly reports to the Office of Water and SPMS (quantitative measures), and midyear reviews (qualitative measures and whatever quantitative data are available at the time of the review). The following is a brief description of the ways in which the Office of Water plans to collect information and to evaluate Regional performance. A. Prenegotiated Comiitments and Quarterly Reporting Many quantitative measures in the accountability system require pre- negotiated commitments. The commitment-setting process will be carried out in conjunction with that of the Strategic Planning and Management System and will follow the same schedule. In July and August of 1985, the Office of Water Program Offices negotiate with the Regions to set specific target levels of activity for the quantitative measures in the accountability system. The Regions and the Office of Water use the following process to reach agreement on all prenegotiated commitments: 0 Program Offices will negotiate targets based on the quantitative measures in the FY 1986 accountability system; the Assistant Admin- istrator must personally approve any requests for prenegotiated commitments beyond those included in the final FY 1986 system. 0 Program Office Directors will initiate the original data requests, which will be addressed to the Regional Water Management Division Directors. 0 Program Office data requests will identify significant program assumptions, reporting frequency, and reporting mode; each data request should cross-reference the pertinent measure in the FY 1986 Office of Water Accountability System. Page 5 ------- Section III The Office of Water Evaluation System Office of Water Evaluation Guide 0 Program Offices will negotiate commitments based on workload and output projections. Negotiations will start from zero base, with Regions developing the initial target; the Program Offices will analyze the Region's output estimates to assure that they are consistent with performance expectations, and will accept the Region's estimates unless there is practical evidence or other valid reason to suggest that an alternative output estimate is more appropriate. 0 Once staff level negotiations are complete, the Assistant Administrator will submit agreed upon canmitments for those measures included in SPMS to the Office of Management Systems and Evaluation (OMSE); copies of enforcement performance commitments are also to be submitted to the Office of Enforcement Compliance and Monitoring (OECM). Regional Administrators will also be asked to submit the SPMS canmitments to OMSE. Oonmitments for those measures included in the Office of Water Accountability System only will be sent by the Assistant Administrator to the Regional Administrator for review and approval. The Regional Administrator should approve the final commitments. By August 30, 1985 Regional Administrators and the Office of Water are required to submit SPMS coimitmeruts. Any disagreements between the Regions and the Office of Water are to be mediated by OMSE and OECM or, if necessary, ultimately resolved by the Deputy Administrator by mid-September. The SPMS Commitments will be published by October 1, 1985. Additionally, an "open season" will be held in October to allow adjustments to canmitments for unanticipated end of fiscal year 1985 activity which significantly effects the FY 1986 targets. These changes will be submitted to OMSE by Regional Administrators and the Assistant Administrator by October 31, 1985. B. Mid-year Evaluations Mid-year evaluations will be based on the quantitative and qualitative measures in the FY 1986 accountability system, and the discussions in each Region will focus on its particular problems and issues. The Office of Water plans to use its established evaluation process in FY 1986. The following is a description of that process. Page 6 ------- Section III The Office of Water Evaluation System Office of Water Evaluation Guide 1. Advance Preparation Early in FY 1986, the Office of Water will begin to schedule the formal evaluations/ which will occur during the months of May, June, and July. Each Region is encouraged to adjust its raid-year evaluations of State water programs so that these reviews are completed prior to the Office of Water evaluation. At least four weeks prior to the scheduled formal evaluation, each Region must provide a summary of Regional and State progress to date in major National program areas. Regions which are not scheduled for a formal evaluation are also expected to submit full self-evaluations to the Office of Water by May 15. These should be succinct self-evaluations in which the Region identifies its key problems and issues, as well as its success(es) to date in meeting National program objectives, based on the measures in the 1986 Office of Water Accountability System. The Region is also encouraged to look back at its FY 1985 end-of-year status, and to provide an analysis of its progress since that time, identifying by program whether it has been outstanding, fully successful, or unsatisfactory. While there is no required format for the self-evaluations, some program offices may provide suggested formats for use by the Regions. The Office of Water will use these summaries as discussion documents during the on-site visits. For those Regions where there is no on-site evaluation, the self-evaluation will be used to evaluate Regional progress and to determine whether issue- specific program audits are necessary. Each Region scheduled to receive an on-site evaluation should also submit a proposed agenda for the Technical Review Session (see below). This proposed agenda should be based upon the Region's review of its state programs and its self-evaluation, and it should highlight areas of special concern to the Region; areas of concern may include technical issues, as well as interpretation of national policy directions. Proposed agendas should include a block of time to discuss the issues that are common across water program areas, as well as unique projects that have involved significant Regional effort during the year. Each Region will be provided with a final agenda at least two weeks in advance of the on-site evaluation. The Office of Water Program Offices will review each Region's evaluation and its proposed agenda, and will identify any additional issues that may be of concern. The Office of Water will then work closely with each Region to modify the agenda based on its review of the Region's self-evaluation, as well as other data collected through routine activities, such as quarterly reporting. Page 7 ------- Section III ihe Office of Water Evaluation System Office of Water Evaluation Guide 2. On-site Evaluations The formal on-site evaluations will consist of a Technical Review Session followed by a Senior Management Session. The duration of the Technical Review Session will be based on the nature and extent of the problems that are identified, and will vary from two to three days in each Region. The Technical Review team will be led by a Division Director. Each of the following program areas will be represented: regulations and standards, permits and enforcement, construction grants, drinking water, ground water, and marine and estuarine programs. The Office of Water will also encourage a senior level manager fron another Region to participate in a review of his or her choosing. The Technical Review Sessions will be conducted as separate breakout sessions in specific program areas. Seme time will also be set aside for full group discussion of issues that cross program areas; this discussion should occur after the breakout sessions so that all participants are informed of the issues. At the conclusion of the Technical Review Session, the Office of Water review team will collaborate with the Region's staff to identify the general issues and findings that both parties agree should be discussed at the follow-up Senior Management Session. The Region will have an opportunity to review this report and to provide further information prior to the follow-up Senior Management Session. The one-day Senior Management Session will occur approximately one week after the initial Technical Review Session. The specific purpose of this meeting is to reach a mutual understanding regarding how the Region plans to deal with key findings and unresolved concerns that emerged during the Technical Review'Session. The group will be led by the Assistant Administrator (AA) or Designee; team members may include the Technical Review Team leader and selected Office Directors. Regional participants should include the Regional Administrator (RA) and/or the Deputy Regional Administrator (DRA), as well as the Water Division Director (WDD), and, if appropriate, the Environmental Services Division Director. The evaluation report that was prepared at the conclusion of the Technical Review Session will serve as the basis for the Senior Management discussion. Prior to the session with the RA or DRA, the Senior Management Team and the WDD will meet to discuss the key issues raised in the report, and, if appropriate, will reach agreement on how the Region plans to deal Page 8 ------- Section III The Office of Water Evaluation System Office of Water Evaluation Guide with these issues. These agreements and any remaining, unresolved issues will be discussed with the RA or DRA in an effort to arrive at decisions regarding how they will be handled. 3. Evaluation Follow-up Following the Senior Management Session, the Office of Water will prepare a memo that summarizes the key issues that were discussed and. outlines any commitments that were made at the Senior Management Session. These memos will not be comprehensive summaries of all the issues discussed, but will focus on critical issues, the agreements that were reached, and other actions (if any) that may be required to resolve any outstanding issues. The Regions are encouraged to respond to these memos and to apprise the Assistant Administrator of actions that resulted from the evaluation findings. For those Regions where there is no on-site evaluation, the Office of Water will analyze the findings from the Regional self-evaluations. Where significant concerns are identified, program audits may be generated. In all cases, the Office of Water will prepare a memorandum to the Region summarizing critical issues and/or identifying areas where performance is satisfactory or outstanding. C. Other Off ice of Water Informationi_ (Collection Activities While the accountability system and the mid-year evaluations will provide the Office of Water with much of the critical information necessary to overview Regional water programs, these reviews are not intended to provide all the data that Program Offices need to monitor ongoing activities in the Regions and States and to respond to special requests from the Congress, the Administrator or the Assistant Administrator. Consequently, there will be a need for Program Offices to collect data and information from the Regions outside the formal accountability system. The Office of Water remains committed to keeping these information requests to a minimum, and to coordinating activities between the Program Offices to the extent possible. The following are the main, ongoing information collection activities that the Office of Water anticipates during FY 1986: 0 Budget; The Office of Water will ask the Regions to provide the information necessary to prepare the annual budget request. Regions will also participate in the workload analysis that serves as the basis for distributing resources among the ___ Page 9 ------- Section III The Office of Water Evaluation System Office of Water Evaluation Guide Regions. Regions may also periodically be asked to provide incidental information related to the budget process. Quarterly Reporting; Regions will submit quarterly, semi-annual or annual reports to the Office of Water to monitor prenegotiated commit- ments where such data cannot be tracked through national data retrieval systems (see above). The Office of Water will supply the appropriate intormation for the Strategic Planning and Management System to the Office of Management Systems and Evaluation. Data Retrieval; The Office of Water will retrieve quantitative data from existing management information systems, such as the Permits Compliance System (PCS), the Grants Information Control System (GICS), and the Federal Reporting Data System (FRDS). Annual Work Programs/Strategies; The Office of Water will review Regional documents that are submitted on a routine basis, such as the section 106/205 (j) work programs, the State section 305 (b) reports, and the annual plans and evaluation results from section 205 (g) delegation agreements. Ihe Office of Water will also review the Regional and State strategies called for in the FY 1985 accountability system. Audits; The Office of Water will continue to conduct selected program audits and case studies on an as needed basis to track critical activities. Examples include staff level audits of the construction grants and permits and compliance programs, which typically will occur prior to the Office of Water mid-year evaluations. The Program Offices will plan and negotiate these essential activities with the Regions, and will conduct these activities jointly to the extent possible. 0 Self -evaluation Reports; Regions will submit mid-year self-evaluations that summarize their progress-to-date as it relates to the Office of Water's national program objectives (see preceding section for details). The information produced by these activities will be used for ongoing program management purposes, and will also be used to help identify issues and concerns that need to be discussed during the mid-year evaluations. Page 10 ------- TIMELINE FOR ACTIVITIES RELATED TO THE FY 1986 OFFICE OP WATER OPERATING GUIDANCE AND ACCOUNTABILITY SYSTEM REGIONAL ACTIVITIES Regions Negotiate State Workplans Based Regions Conduct on FY 1986 Guidance/ Reviews of Accountability State Programs I 1 1 * * Oct Nov Dec Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Jan Feb Mar Apr t 1 1 1 1 1 1 1 1 I 1 1 1 1 1 FY 1985 1 1 FY 1986 J * * lay Jun Jul Aug Sep Oct FY 1987 Agency Publishes FY 1986 Guidance/Accountability; OW/Regions OW Conducts GW Publishes Account- Negotiate FY 1986 Mid-year Evaluations of ability System and Caimitments for Regional Water Programs Evaluation Guide SPMS/OWAS (Reports submitted in * months) OFFICE OF WATER ACTIVITIES ------- APPENDIX A ------- MUNICIPAL POLLUTION CONTROL: OBJECTIVE: IMPROVE VOTER QUALITY (pg. 35) ACTIVITIES 1. Manage Priority System and Lists QUALITATIVE MEASURES FOR MID-YEAR REVIEWS (A) Can the Regions/States demonstrate that grant dollars are going to high priority HQ/PH projects based on an accepted project priority list? How do these projects correlate with the priority waterbodies as stated in 40 CFR 35.2005(B) 34 and identified in the Water Quality Standards, Planning, and Assessment Section of GNAS? QUANTITATIVE MEASURES IN SPMS/ COMMITMENT? REPORTING FREQUENCY Ongoing SOURCE OF DATA Needs Survey Inventory, Region/ State Monitor- ing and Tracking Records. Reports & Hard- Copy of accepted PPL Showing Ranking. GICS Reports & OWRS Data on Priority Water- bodies. ------- MUNICIPAL POLLUTION CONTROL; OBJECTIVE: ENSURE FINANCIAI/TECHNICAL PROGRAM MANAGEMENT (pg. 35) ACTIVITIES 1. Stimulate development or improvement of State sludge ragnt. programs. ro 2. Assure compliance with Federal sludge use & disposal requirements through existing or new State sludge ngnt. programs. QUALITATIVE MEASURES FOR MID-YEAR REVIEWS (A) What actions have the Regions taken, or plan to take, to assist the States in developingr evaluating, and improving their sludge management programs? (B) What actions have the Regions taken, or plan to take, to assist the State in developing sludge ngnt. programs or revising the existing programs to con- form with new Federal sludge use and disposal requirements? (C) What plans have the Regions made for coordinating overall Regional activities related to sludge ragnt. issues? (A) What EPA manpower resources would be required for the Regions to directly impose Sec. 405 requirements in States without acceptable sludge ragnt. programs in place? QUANTITATIVE MEASURES IN SPMS/ COMMITMENT? REPORTING FREQUENCY SOURCE OF CATA ------- MUNICIPAL POLLUTION CONTROL; OBJECTIVE: ENSURE FINANCIAL/TECHNICAL PROGRAM MANAGEMENT (pg. 35) ACTIVITIES QUALITATIVE MEASURES FOR MID-YEAR REVIEWS QUANTITATIVE MEASURES IN SPMS/ COMMITMENT? REPORTING FREQUENCY SOURCE OF DATA 3. Manage the Program to Ensure Priority Legislative Requirements are Effec- tively Im- plemented. u> (A) Is the Region/delegated State management approach achieving maximum utiliza- lation of the I/A set-aside? What criteria does the Region utilize to ensure consistent, high quality designations of I/A technology? (B) Are the Regions/States managing the VE program to assure maximum savings are achieved? (C) How are the Regions and States implementing the ICR recommendations resulting from the PY 1985 program review? (D) What is the Regional/State strategy for managing the one- year project performance certi- fication process? (E) Have the grantees with projects that were non-affirma- tively certified at the con- clusion of the one year period (based on actual N7 + 12 months) submitted acceptable corrective action reports and what are the States and Region doing to ensure that progress is being achieved in correcting the problems? (a) % of projects that completed the one year opera- tional period and were affirma- tively certified. No/No Second/ Fourth Quarters GICS Report to be deve- loped ------- MUNICIPAL POLLUTION CONTROL: OBJECTIVE: ENSURE FINANCIAI/TECHNICAL PROGRAM MANAGEMENT (pg. 35) T ACTIVmES 4. Assure that Pro- jects are within the financial and management capability of the community and users, and are technolog- ically appropriate 5. Conduct and Evaluate AT Reviews 6. Evalu- ate Dele- gated CSO Projects QUALITATIVE MEASURES FOR MID-YEAR REVIEWS (A) Is the Region over- seeing delegated states to ensure compliance with 40 CFR 35. 2104(b), 35.2140, and to ensure that wastewater treatment works are operating on a self-sustaining basis? (B) How does the Region/ State screen and resolve potential problem projects including inappropriate technology? (A) Does sufficient docu- mentation exist, as a result of Region/State reviews, to demonstrate that each of the proposed AT processes would definitely result in signifi- cant water quality and public health improvements (i.e., number of projects where AT processes are approved, and number of AT projects deferred due to insufficient justifi- cation)? (A) Have the States demonstrated that fishing and swimming benefits would result from each CSO project funded under section 201(n)(l)? QUANTITATIVE MEASURES IN SPMS/ COMMITMENT? REPORTING FREQUENCY SOURCE OF DATA ------- MUNICIPAL POLLUTION CONTROL; OBJECTIVE: ENSURE EFFECTIVE CONSTRUCTION AND PREVENT BACKLOGS (pg. 37) ACTIVITIES 1. Elimi- nate Back- logs and Manage Grants Efficiently gUALITATIVE MEASURES FOR MID-YEAR REVIEWS (A) Does the Region have an effective strategy for managing project schedules for all municipal treatment works construction projects (including projects that are not grant funded) which is consistent with the National Municipal Policy? QUANTITATrVE MEASURES (a) Total dollar value (grant amounts) in pre- construction lag status expressed as a percent of annual allotment. (b) # of projects initiating operation. (c) # of Step 3, Step 2+3 & PL 84-660 administrative completions. (d) # of Step 3, Step 2+3 & PL 84-660 closeouts. (e) # of administrative completion backlogs eliminated. (f) # of closeout backlogs eliminated. IN SPMS/ COMMITMENT? No/No REPORTING SOURCE FREQUENCY OF DATA Quarterly CGP-008 CGP-0086 Yes/SPMS WQ-17 No/OW No/OW Yes/SPMS WQ-16 No/OK Quarterly CGP-2330 CGP-2270 Quarterly CGP-2330 CGP-2280 Quarterly CGP-2330 CGP-2310 Quarterly CGP-2345 Quarterly CGP-2558 ------- MUNICIPAL POLLUTION CONTROL; OBJECTIVE: ENSURE EFFECTIVE CONSTRUCTION AND PREVENT BACKLOGS (pg. 37) ACTIVITIES 1. Eliminate Backlogs and Manage Grants Efficiently (cont.) T QUALITATIVE MEASURES FOR MID-YEAR REVIEWS (B) What tools do the Regions/States use to minimize unliquidated balances in SMPs? (C) Are CMEs and FMCs used effectively with well trained team members to help assess the overall evaluation of the grant program? (D) Is a PMC conducted on all Step 3 and Step 2+3 projects where grantees are not sufficiently experienced? (E) Is there a project specific strategy, with time based goals, for completing all Step 1 & Step 2 projects? (F) What actions have the Region and States taken to manage a claims reduction program? QUANTITATIVE MEASURES (g) % reduction of un- liquidated obligations in a negotiated group of "slow moving" projects (SMPs). (h) f of CMEs. IN SPMS/ COMMITMENT? NO/OW REPORTING SOURCE FREQUENCY OF DATA Quarterly CGP-2565 No/OW Quarterly Regional Submis- sion (i) f of active Step 1's and Step 2's administratively completed or terminated during the year. No/OW Quarterly CGP-2500 CGP-2510 ------- MUNICIPAL POLLUTION CONTROL; OBJECTIVE: ENSURE EFFECTIVE CONSTRUCTION AND PREVENT BACKLOGS (pg. 37) ACTivrriES 2. Manage State/Regional Grant Disputes Resolution Procedures and Tracking Systems to Monitor States 3. Oversee the Corps IAG to See that Work- plan Com- mitments are Achieved QUALITATIVE MEASURES FOR MID-YEAR REVIEWS (A) What are the time-based goals that have been incorpo- rated into the steps of the Regional disputes process (i.e.r scheduling of informal conference, completion of draft decision, completion of final decision) in order to resolve disputes in a timely manner? (B) Is the Region over- seeing the Corps IAG to ensure that negotiated resource and output cormitments are met? QUANTITATIVE MEASURES IN SPMS/ COMMITMENT? REPORTING FREQUENCY SOURCE OF DATA (a) % of Corps utili- zation vs. target. No/No Quarterly (b) I of final construction inspections conducted by the COE. (c) I of Project Management Conferences (PMC's) conducted by the COE. Nc/OW Quarterly No/OW Quarterly Report- ing Deve- loped by Corps Divi- sions and Region Reporting Developed by Corps Divisions and Region Reporting Developed by Corps Divisions and Region ------- MUNICIPAL POLLUTION CONTROL; OBJECTIVE: IMPROVE STATE/REGIONAL PROGRAM MANAGEMENT (pg. 38) ACTIVITIES 1. Complete Delegation of the Construc- tion Grants Program to the States > 00 QUALITATIVE MEASURES FOR MID-YEAR REVIEWS (A) What is the Region doing to overcome obstacles in delegat- ing all delegable functions to the States? Are the delegation agree- ments current? (B) Demonstrate that a plan for overview pursuant to 40 CFR 35.3025 (a) has been developed and that an en-site evaluation has been performed. (C) Is the Region managing GICS so that it is reliable and accurate, supportive of program priorities, serves as an effective outreach program to delegated States and is readily available to end-users? (D) What is the Region's strategy and implementation plan for levels of Regional construction grants program human resources, skill mix and staffing patterns to meet delegated state oversight and technical assistance responsibilities, and direct EPA construction grant and O&M management responsibil- ities? QUANTITATIVE MEASURES (a) # of new activities delegated to the States IN SPMS/ COMMITMENT? NO/NO REPORTING FREQUENCY Second/ Fourth Quarters SOURCE OF DATA Delega- tion Matrix Submitt- ed by Region ------- > vo MUNICIPAL POLLUTION CONTROL: OBJECTIVE: IMPROVE STATE/REGIONAL PROGRAM MANAGEMENT (pg. 38) ACTIVITIES 2. Manage Program to Meet Out- lay and Obligation Projections QUALITATIVE MEASURES FOR MID-YEAR REVIEWS (A) What measures are being taken by Region/States/COE to keep on track? QUANTITATIVE MEASURES (a) % of cum. net outlays to commitment. IN SPMS/ COMMITMENT? Yes/SPMS WQ-15 REPORTING FREQUENCY Monthly/ Quarterly SOURCE OF DATA Financial Manage- ment Report CGM-15 (B) What are net obligations on a state-by-sjbate, source- by-source, quarter-by-quarter basis? (b) % of cum. gross obligations to commitment. No/OW Quarterly Financial Manage- ment Report EPA 92-500 ------- MUNICIPAL POLLUTION CONTROL: OBJECTIVE: IMPROVE PERFORMANCE OF COMPLETED FACILITIES (pg. 37) ACTIVITIES QUALITATIVE MEASURES FOR MID-YEAR REVIEWS QUANTITATIVE MEASURES IN SFMS/ COMMITMENT? REPORTING FREQUENCY SOURCE OF DATA 1. Improve Facilities Performance (A) Are States effec- tively implementing an onsite operator training and technical assistance program for bringing small facilities into improved compliance? How many minor POTW's have the States com- mitted to assist under 104(g) 1 grants and are they on schedule? How many POTW's have returned to compliance following an OME? (a) # of operations Management Evaluations (OMEs) performed at completed minor POTW's. Yes/SPMS WQ-18 Second/ Fourth Quarter GICS Report to be deve- loped ------- PERMITS: OBJECTIVE: ELIMINATE THE BACKLOG OF EXPIRED MAJOR NPDES PERMITS CONSISTENT WITH NATIONAL POLICY AND GUIDANCE AND ISSUE PERMITS AS THEY EXPIRE. ISSUE MINOR NPDES PERMITS, ESPECIALLY PERMITS FOR ENVIRONMENTALLY SIGNIFICANT MINORS AND UNPERMITTED DISCHARGERS (pg. 28) ACTIVITIES 1. Issue/Reissue Industrial and Municipal Permits QUALITATIVE MEASURES FOR MID-YEAR (A) How were Regional/State permit issuance strategies de- veloped and how does the Region track State permit issuance status (major and minor)? (B) Have the Region/States developed priority lists for issuing industrial/muni- cipal permits? Did they use national policy and guidance to develop a priority list for permit issuance? Are resources being directed to deal with the roost significant toxic discharge or water quality problem areas? (C) Do any States have a a continuing backlog of expired major permits? QUANTITATIVE MEASURES (a) Track progress against targets for the # of permits reissued to major industrial facilities during fiscal year (NPDES States, non-NPDES states). (b) Identify the # of major in- dustrial permits that have or will expire by the end of FY 86 (NPDES States, non-NPDES States). IN SIMS/ COMMITMENT? Yes/SPMS WQ-2/WQ-4 REPORTING FREQUENCY Quarterly SOURCE OF DATA PCS Yes/No WQ-l/WQ-3 (c) Track progress against tar- Yes/SPMS gets for the # of permits reissued WQ-6/VJQ-8 to major municipal facilities during fiscal year (NPDES States, non-NPDES States). (d) Identify the I of major Yes/No municipal permits that have WQ-5/WQ-7 or will expire by the end of FY 86 (NPDES States, non- NPDES States). (e) Region's lists of major No/OW industrial and municipal permits to be issued in non- NPDES States in FY86. (f) NPDES State's lists of major No/OW industrial and municipal permits to be issued in FY 86. 10/10/85 Quarterly PCS PCS 10/10/85 PCS Provide Region lists start of FY Provide lists to Region start of FY States ------- trwirrs: 1. Issue/ Reissue Industrial and Municipal Perndta (oont.) 10 OBJBCTIVEi ELIMINATE TOE BACKLOG OP EXPIRED MAJOR NPDES PERMITS CONSISTEOT WITH NATIONAL POLICY AND GUIDANCE AND ISSUE PERMITS AS THEY EXPIRE. ISSUE MINOR NPDES PERMITS, ESPECIALLY PERMITS FOR ENVIRONMENTALLY SIGNIFICANT MINORS AND UNPERMHTED DISCHARGERS (pg. 28) QUALITATIVE MEASURES FOR MID-YEAR Has the Region assessed the reasons? What are the Region's plans to address the problem!? (D) Are industrial/muni- cipal major permit issuance rates in the Region/States expected to be sufficient to assure residual backlogs do not exceed 10%? Now? In the future? (E) Are there delays or roadblocks in the Region's/ States' industrial/muni- cipal permitting processes? What are they and vfoat practical steps are noodod to expedite permitting? (F) Are permits that were held by the Region/ States for reissuanoe pending final effluent guidelines being issued by Region/States upon QUANTITATIVE MEASURES IN SPMS/ COMMITMENT? (g) Track I of major industrial No/No permits modified (NPDES States, non-NPDES States). (h) Track I of major No/No municipal permits modified (NPDES States, non-NPDES States). (i) Track progress against Yes/SPMS targets for the t of permits WQ-9 reissued to significant minor industrial facilities during fiscal year (NPDES States, non-NPDES States). (j) Track progress against Yes/SPMS targets for the t of permits WQ-9 reissued to significant minor municipal facilities during fiscal year (NPDES States, non-NPDES States). (k) Prepare strategy for each No/OW State for the issuance of permits to minor dischargers. REPORTING FREQUENCY of FY Quarterly Quarterly Second and Fourth Quarters SOURCE OF DATA Region Region Region/ States Second and Fourth Quarters 7/1/86 Region/ States Region/ States ------- PERMITS: OBJECTIVE: ELIMINATE THE BACKLOG OF EXPIRED MAJOR NPDES PERMITS CONSISTENT WITH NATIONAL POLICY AND GUIDANCE AND ISSUE PERMITS AS THEY EXPIRE. ISSUE MINOR NPDES PERMITS, ESPECIALLY PERMITS FOR ENVIRONMENTALLY SIGNIFICANT MINORS AND UNPERMITTED DISCHARGERS (pg. 28) ACTIVITIES 1. Issue/Reissue Industrial and Municipal Permits (cont.) O) QUALITATIVE MEASURES FOR MID-YEAR (G) How was the July 1984 deadline addressed by the Region/States? Were short- term permits issued? Will many permits have reopener clauses for incorporating promulgated effluent guide- lines or for addressing new limits resulting frcm toxicity testing? (H) What is the nature of the modifications being made to industrial/municipal major permits? Discuss this workload for the Region/States in re- lation to permit issuance and other permitting activities. What are the resource implica- tions? How does the Region track permit modifications? (I) Discuss in particular the process and timing for modifi- cation of municipal permits to incorporate approved pretreat- ment program requirements. Have all approved local programs been incorporated in permits? If QUANTITATIVE MEASURES IN SIMS/ COMMITMENT? REPORTING FREQUENCY SOURCE OF ------- PERMITS: OBJECTIVE: ELIMINATE THE BACKLOG OP EXPIRED MAJOR NPDES PERMITS CONSISTENT WITH NATIONAL POLICY AND GUIDANCE AND ISSUE PERMITS AS THEY EXPIRE. ISSUE MINOR NPDES PERMITS, ESPECIALLY PERMITS FOR ENVIRONMENTALLY SIGNIFICANT MINORS AND UNPERMITTED DISCHARGERS (pg. 28) ACTIVITIES 1. Issue/Reissue Industrial and Municipal Permits (oont.) 2. Issue New Source/Major New Discharger Permits QUALITATIVE MEASURES FOR MID-YEAR QUANTITATIVE MEASURES not, what are the impediments? When will it be done? Are subse- quent local program changes being incorporated? How frequently does this happen? Is there a backlog? What priority is given to assuring municipal permits are modified to reflect current local pretreatment programs? (A) Is Region's/States' approach to new permits consistent with priority to protect water quality? Are there special prob- lems in the new source area? Is there adequate coordination with other media programs where more than one EPA permit is re- quired? Is construction ban being enforced? Have problems arisen in this area? Are NEPA reviews conducted smoothly and in a timely manner where re- quired? (a) Identify f of complete applications for new source/ major new dischargers in non- NPDES States that are on hand (i.e., complete applica- tions) at the beginning of FY85 and the f pending for more than 12 months. (b) Track # of new source/ major new discharge permits issued, the f of complete applications on hand at the end of the quarter, and the I of completed applications pending more than 12 months at the end of the quarter. IN SPMS/ COMMITMENT? REPORTING FREQUENCY SOURCE OF DATA No/No 10/31/85 Region No/No Quarterly Region ------- PEROTS: OBJECTIVE: ELIMINATE THE BACKLOG OF EXPIRED MAJOR NPDES PERMITS CONSISTENT WITH NATIONAL POLICY AND GUIDANCE AND ISSUE PERMITS AS THEY EXPIRE. ISSUE MINOR NPDES PERMITS, ESPECIALLY PERMITS FOR ENVIRONMENTALLY SIGNIFICANT MINORS AND UNPERMITTED DISCHARGERS (pg. 28) ACTIVITIES 3. Issue/Reissue General Permits in QUALITATIVE MEASURES FOR MID-YEAR (A) What types of problems have the Region/States en- countered in issuing general permits? What measures have been taken or are needed to resolve them? (B) Is Region actively considering ways to use general permits to reduce municipal permits are modified to reduce minor permit back- log? What types of general permits are being considered? To what extent will they reduce the minor permit backlog? When are they likely to be issued? (C) To what extent can general permits be used to regulate un- permitted dischargers? Are any such general permits being prepared? When are they likely to be issued? How many un- permitted dischargers would be regulated? QUANTITATIVE MEASURES (a) Track progress against targets for the # of general permits issued/reissued (non-NPDES States): -OCS general -f in new categories (not covered by prior EPA general permits); and -# others (covered by prior general permits). (b) Track # of general permits issued/reissued (NPDES States): -OCS general -# in new categories (not covered by prior EPA general permits); and -f others (covered by prior general permits). IN SPMS/ COMtTTMENT? No/OW REPORTING FREQUENCY SOURCE OF DATA Quarterly Region No/OW Second and Fourth Quarters States ------- PERMITS t OBJECTIVE: ENSURE THAT INDUSTRIAL AND MUNICIPAL NPDES PERMITS INCLUDE APPROPRIATE REQUIREMENTS, INCLUDING PRETREATMENT AND BIOMONITORING (pg. 28) 1. Develop Appropriate and Enforce- able Permit Conditions T H-" o\ QUALITATIVE MEASURES FOR MID-YEAR (A) Are States/Region adhering to established processes for writing WQ based permits? Dis- cuss problems encountered and how they were addressed. (B) Discuss Region's/States' implementation of the "Policy for the Development of Water Quality-based Permit Limita- tions for Toxic Pollutants." Have EPA and the States been working together to implement the policy? What steps have been taken so far? Have procedures been developed? (C) Have the Region/States iden- tified permittees with potential water quality impacts that will be required to do toxicity testing? Do any permits now contain toxicity testing requirements? Are §308 letters (or similar State mechanisms) being used in lieu of permit condi- tions? Have any toxicity-based ef- fluent limits been incorporated into permits? Discuss Region's/States' experiences« problems. QUANTITATIVE MEASURES IN SPMS/ COMMITMENT? REPORTING FREQUENCY SOURCE OF DATA ------- PERMITS; OBJECTIVE: ENSURE THAT INDUSTRIAL AND MUNICIPAL NPDES PERMITS INCLUDE APPROPRIATE REQUIREMENTS, INCLUDING PRETREATMENT AND BIOMONITORING (pg. 28) ACTIVITIES 1. Develop Appropriate and Enforce- able Permit Conditions (cont.) QUALITATIVE MEASURES FOR MID-YEAR (D) Discuss any problems encountered by Region/ States with respect to permit monitoring require- ments and general conditions. (E) Are States/Region en- countering any difficulties in applying the guidelines? If so, how are they being resolved? Are the resolu- tions satisfactory and timely? (F) To what extent are States/ Region developing permit conditions using best profes- sional judgement? Is the technical support for these judgements adequate? If not, what additional support is needed? Are the resolutions satisfactory and timely? (G) Do many of the Region's/ States' industrial permits contain BMP requirements? How are these requirements written into permits? Is the guidance developed by Headquarters adequate or are additional information or workshops needed on BMPs? QUANTITATIVE MEASURES IN SPMS/ COMMITMENT? REPORTING FREQUENCY SOURCE OF DATA ------- OBJECTIVE: ENSURE THAT INDUSTRIAL AND MUNICIPAL NPDES PERMITS INCLUDE APPROPRIATE REQUIREMENTS, INCLUDING PRETREATMENT AND BIGMONITORING (pg. 28) ACTIVITIES 1. Develop Appropriate and Enforce- able Permit Conditions (cent.) 00 QUALITATIVE MEASURES FOR MID-YEAR (H) Are States/Region identifying toxic dis- charge problem areas where post-BAT limita- tions are needed? Discuss how these areas are being identified and hew bio- nDnitoring techniques are being used to determine appropriate limits. (I) Are Region's/States' municipal permit conditions consistent with the new secon- dary treatment definition? Are there any difficulties in applying the new definition? If so, how are they being resolved? Are the resolutions satisfactory and timely? Discuss the nature and extent of the use of "special consideration" provisions of the secondary treatment definition. (J) To what extent do Region's/ States' municipal permits contain monitoring and reporting requirements for toxics in their effluent and/or sludge. QUANTITATIVE MEASURES IN SPMS/ OOJMITMENT? REPORTING FREQUENCY SOURCE OF DATA ------- PERMITS t OBJECTIVE: ENSURE THAT INDUSTRIAL AND MUNICIPAL NPDES PERMITS INCLUDE APPROPRIATE REQUIREMENTS, INCLUDING PRETREATMENT AND BIOMONITORING (pg. 28) ACi'lVlTltai 1. Develop Appropriate and Enforce- able Permit Conditions (cent.) vo QUALITATIVE MEASURES FOR MID-YEAR (K) Are there any remaining problems developing permit oonplianoe schedules for facilities eligible for §301(i) extensions? If so What is the nature of the problems and how are the Region/States resolving them? (L) Discuss Region's/States' progress in completing muni- cipal permit modifications for §301 (h) and pretreatment, and any problems associated with permit monitoring requirements and general conditions. (M) Are requirements of RCRA being translated by Region/States into new conditions in reissued/ modified NPDES permits? What are the requirements? Is their de- velopment significantly changing usual permit processing, timing or resource needs? If so, how? Are any difficulties in issuing NPDES with these conditions arising in the public sector or in the regu- lated connunity? If so, what are they and what is being done to resolve them? QUANTITATIVE MEASURES IN SPMS/ COMMITMENT? REPORTING FREQUENCY SOURCE OF DATA ------- PERMITS: ACTIVITIES 2. Resolve Evidentiary Hearings OBJECTIVE: ENSURE THAT INDUSTRIAL AND MUNICIPAL NPDES PERMITS INCLUDE APPROPRIATE REQUIREMENTS, INCLUDING PRETREATMENT AND BIQMQNITORING (pg. 28) QUALITATIVE MEASURES FOR MID-YEAR (A) What are the Region's/ States'plans for elimina- ting the present hearing backlog? Discuss Water Division/Regional Counsel coordination on resolving backlogged hearings and on addressing new hearing re- quests. Are any hearing requests related to the redefinition of secondary treatment or S301(h) per- mits? (B) What are the Region's/ States' major issues? Has a pattern developed that in- dicates a need for program changes, including procedures, regulations, policy, guidance, technical assistance, etc? QUANTITATIVE MEASURES (a) Identify # of evidentiary hearing requests pending at beginning of FY 86 (NPDES States, non- NPDES States): - Municipal; and - Non-municipal. (b) Track against targets the f of evidentiary hearing requests pending at beginning of FY that were resolved in FY 86 (NPDES States, non-NPDES States): - Municipal; and - Non-Municiapl. (c) Identify f of evidentiary hearings requested during FY 86 (NPDES States, non-NPDES States): - Municipal; and - Non-municipal. (d) Track i of evidentiary hearing requests received in FY 86 which are denied or granted within 90 days (NPDES States, non-NPDES States): - Municipal; and - Non-municipal. IN SPMS/ COMMITMENT? Yes/No WQ-10 REPORTING FREQUENCY 10/15/85 SOURCE OF DATA Region/ States Yes/SPMS WQ-11 Quarterly Region/ States No/No Quarterly Region/ States No/No Quarterly Region/ States ------- PERMITS i OBJECTIVE: ENSURE THAT INDUSTRIAL AND MUNICIPAL NPOES PERMITS INCLUDE APPROPRIATE INCLUDING PRETREATMENT AND BIGMONITORING (pg. 28) ACTIVITIES 3. Review and Approve/Deny Variance Requests N> QUALITATIVE MEASURES FDR MID-YEAR (A) How is the Region's/ States' variance process working? What are the dif- ficulties? What additional support is needed, such as procedural changes, guidance or support from Headquarters? Discuss problems and successes. (B) Have any States requested Alternative State Requirements (ASRs) under the redefinition of secondary treatment? Discuss the review and approval process and identify any problems or support needs. In States where EPA is the NPDES authority, have any cities asked for ASR limits (i.e. higher effluent nunbers than 45 rag/1 BOD and sus- pended solids)? Discuss the Region's response to the municipal inquiry. Was the State informed of the ASR inquiry? QUANTITATIVE MEASURES (a) Identify * of direct discharger variance re- quests pending at begin- ning of FY 86 (NPDES States, non-NPDES States): - FDF - 301(c) - 301(g) - 301(k) - 316(a) - 316(b) (b) Track against targets the # of direct discharger variances denied-or for- warded to Headquarters with a recommendation in FY 86 (NPDES States, non- NPDES States): - FDF - 301(c) - 301(g) - 301 (k) - 316(a) - 316 (b) IN SPMS/ COMMITMENT? No/No REPORTING FREQUENCY 10/31/85 SOURCE OF DATA No/OW Quarterly ------- PERMITS: OBJECTIVE: ENSURE THAT INDUSTRIAL AND MUNICIPAL NPDES PERMITS INCLUDE APPROPRIATE REQUIREMENTS, INCLUDING PRETREATMEOT AND BICM3NITORING (pg. 28) ACTIVITIES 3. Review and Approve/Deny Variance Requests (oont'd) QUALITATIVE MEASURES FDR MID-YEAR K> 10 QUANTITATIVE MEASURES (c) Identify f of direct discharger variances re- quested during 5Y 86 (NPDES States, non-NPDES States): - FDP - 301(c) - 301(g) - 301 (k) - 316(a) - 316 (b) (d) Track f of direct discharger variances re- quested during EY 86 which are denied or forwarded to Headquarters with a recom- mendation in FY 86 (NPDES States, non-NPDES States): - FDF - 301(c) - 301(g) - 301 (k) - 316(a) - 316(b) IN SPMS/ OCMMITMEOT? No/No REPORTING FREQUENCY Quarterly SOURCE OF DATA Region/ States No/No Quarterly Region/ States ------- ENFORCEMENT: OBJECTIVE: IMPROVE COMPLIANCE WITH NPDES PERMIT EMPHASIS ON MUNICIPAL COMPLIANCE, (pg. 30) AND ENFORCEABLE SCHEDULES, WITH SPECIAL ACTIVITIES 1. Identify Compliance Problems QUALITATIVE MEASURES FOR MID-YEAR REVIEWS * ts» U> (A) Do the Region's/ States' compliance rates show improvement over the same period in FY 1985? (B) What are the major reasons for municipal/ nonmunicipal noncompliance in the Region/States? (C) How many/what type of facilities are coming back into compliance without any formal enforcement action? Informal action? (D) What are the reasons behind persistent non- compliance, and what is the Region's/States' strategy for dealing with such noncompliance? QUANTITATIVE MEASURES (a) MOVING BASE UNIVERSE; f of major permittees and P.L. 92-500 minor permittees that are: - on final effluent limits (list separately: municipal, non-municipal, federal, P.L.92-500; NPDES States, non-NPDES States); and - not on final effluent limits (list separately: municipal, non-municipal, federal; NPDES States, non-NPDES States). (See Appendix B) (b) MOVING BASE SNC; •# and % of major permittees and P.L. 92-500 minor permit- tees in significant non- compliance (SNC) with: - final effluent limits (list separately: municipal, non-municipal, federal, P.L. 92-500; NPDES States, non-NPDES States); - construction schedules; - interim effluent limits (list separately: municipal, non-municipal, federal; NPDES States, non-NPDES States). (See Appendix B) IN SPMS/ COMMITMENT Yes/No WQ/E-1 through WQ/E-8 Yes/No WQ/E-1 through WO/E-8 REPORTING FREQUENCY Majors; Quarterly Minor P.L.92-500s; Semi- annually (April 1, 1986 based on Dec. 31, 1985 data. Oct. 1, 1986 based on June 30, 1986 data.) Majors; Quarterly Minor P.L. 92-500S! Semi- annually (April 1, 1986 based on Dec. 31, 1985 data. Oct. 1, 1986 based on June 30, 1986 data.) SOURCE OF DATA PCS Data lagged one qtr Region/ State QNCR Data lagged one qtr Region/ State ------- ENFORCEMENT: OBJECTIVE: IMPROVE COMPLIANCE WITH NPDES PERMIT REQUIREMENTS AND ENFORCEABLE SCHEDULES, WITH SPECIAL EMPHASIS ON MUNICIPAL COMPLIANCE, (pg. 30) 2. Expand Enforcement Efforts Under the National Municipal Policy !> 4S QUALITATIVE MEASURES FOR MID-YEAR REVIEWS (A) Are the State Municipal Compliance Strategies being effectively utilized by the Regions and States? Are they updated annually? (B) To what extent are the Region/States still establish- ing permit/compliance schedules for all remaining POTWs? (C) To what extent are the Region/States initiating civil referrals for unfunded POTWs that cannot meet the 1988 deadline? Are these POTWs required to take inter- mediate steps in the mean- time? How are reasonable deadlines being determined? (D) How axe the Region/ States tracking compliance with milestones in permits/ enforceable schedules? What problems are being encountered? Is there a need to seek judicially- imposed schedules in any of these cases? QUANTITATIVE MEASURES (a) COMPOSITE CORRECTION PLANS (1) identify the f of noncom- ~ plying POTWs that need no further construction. (2) Of the POTWs that need no further construction: - f of those for which action to obtain compliance has been required in a schedule (CCP) incorporated into an enforceable document (tracked against target); and - f of those completing the final step of their CCP and returned to compliance (list separately: major, minor; NPDES State, non-NPDES State). (b) MUNICIPAL COMPLIANCE PLANS (1) Identify the I of nan plying POTWs that require construction (2) Of the POTWs that currently require further construction: - f of those for which compliance schedules (MCPs) have been established through an enforceable document (tracked against target); and IN SPMS/ COMMITMENT Yes/No WQ-13 Yes/SPMS- Major, Minor WQ-14 No/No REPORTING FREQUENCY 10/15/85 Quarterly SOURCE OF DATA Region/ State Region/ State Quarterly Region/ State Yes/No WQ-13 Yes/SPMS- Major, Minor WQ-14 10/15/85 Quarterly Region/ State Region/ State ------- ENFORCEMENT; OBJECTIVE: IMPROVE COMPLIANCE WITH NPOES PERMIT REQUIREMENTS AND ENFORCEABLE SCHEDULES, WITH SPECIAL EMPHASIS ON MUNICIPAL COMPLIANCE, (pg. 30) QUALITATIVE MEASURES FOR IN SPMS/ REPORTING SOURCE ACTIVITIES MID-YEAR REVIEWS QUANTITATIVE MEASURES COMMITMENT FREQUENCY OF DATA 2. Expand Enforcement (E) How do the Region/States - t of those completing the No/No Quarterly Region/ Efforts coordinate permit issuance/ final step of their MCP State Under the compliance, and construction and returned to compliance National grant acitivities to improve (list separately: major, Municipal municipal compliance? minor; funded, unfunded; Policy NPDES States, non-NPDES (Cont'd) States). :> in ------- ENFORCEMENT; OBJECTIVE: IMPROVE COMPLIANCE WITH NPDES PERMIT REQUIREMENTS AND ENFORCEABLE SCHEDULES, WITH SPECIAL EMPHASIS OS MUNICIPAL COMPLIANCE, (pg. 30) ACTIVITIES 3* Improve Quality and Timeliness of Enforcement Responses > to QUALITATIVE MEASURES FOR MID-YEAR REVIEWS (A) Are the Region/States working in conjunction with Federal facility coordinators to improve enforcement response times to instances of nonconpliance by Federal facilities? (B) Do the Region and States ensure that the use of AOs/NOVs is consistent with EMS principles and the enforcement response guide? How do the Region and States measure the effective- ness of AOs and NOVs? (C) How do Region/States evaluate the quality of AOs? What is the quality of the AOs? (D) Do Region/States track AO requirements closely? Have all close-outs been reported to Hpylfrrv*'rtgrs? Are they reported promptly upon close-out? QUANTITATIVE MEASURES IN SPMS/ COMMITMENT REPORTING FREQUENCY SOURCE OF DATA (a) ADMINISTRATIVE ORDERS (AOs) f of EPA AOs or State equivalent actions issued: - municipal permittees (major/ minor) - non-municipal permittees (major/minor) - Federal permittees (major/ minor) (list separately: EPA, NPDES States). Yes/No WQ/E-15 Quarterly GREAT, PCS or Region/ State (b) CLOSE-OUT UNIVERSE * of EPA AOs which are to be closed-out between October 1, 1985 through September 30, 1986. Yes/No WQ/E-17 October 1, 1985 Region/ State ------- ENFORCEMENT: OBJECTIVE: IMPROVE COMPLIANCE WITH NPDES PERMIT REQUIREMENTS AND ENFORCEABLE SCHEDULES, WITH SPECIAL EMPHASIS ON MUNICIPAL COMPLIANCE, (pg. 30) ACTIVITIES 3. Improve Quality and Timeliness of Enforcement Responses (Cont'd) 10 ••J QUALITATIVE MEASURES FOR MID-YEAR REVIEWS (E) Are AOs being issued for noncompliance with Spill Prevention Control and Gountermeasure (SPCC) Plan requirements? (F) How do the Region and States ensure that vio- lations of Court Orders get prompt enforcement action? (G) What are the criteria the Region/States use to select referral cases? What is the involvement of ORC in this selection? (H) What is the level of coordination between the compliance section and ORC in the Region and the res- pective agencies in the States? If less than satis- factory, what steps is Region taking to improve coordination? (I) Discuss the quality of the referral packages. Do all refer- ral packages contain appropriate civil penalties that conform with FY 1985 guidance? QUANTITATIVE MEASURES (c) CLOSE-OUTS ACHIEVED # and % of (b) which are successfully closed-out (the final step is achieved or action is referred to Headquarters or DOJ. (d) REFERRALS # of §309 referrals or State equivalent actions generated: - civil referrals sent to HQ/DOJ/SAG; - civil referrals filed; and - criminal referrals filed (list separately: EPA, NPDES States). IN SPMS/ COMMITMENT Yes/SPMS WQ/E-18 REPORTING FREQUENCY Quarterly SOURCE OF DATA Region/ State Yes/No WQ/E-16 Quarterly DOCKET System and Region/ State ------- ENFORCEMENT? OBJECTIVE: IMPROVE COMPLIANCE WITH NPDES PERMIT REQUIREMENTS AND ENFORCEABLE SCHEDULES, WITH SPECIAL EMPHASIS ON MUNICIPAL COMPLIANCE, (pg. 30) ACTIVITIES 3* Improve Quality and Timeliness of Enforcement Responses (cont.) ro oo QUALITATIVE MEASURES FOR MID-YEAR REVIEWS (J) What is the quality of active consent decrees? How closely are they tracked by the Region/States? (K) What types of action are being taken in response to violations of consent decrees? Are stipulated penalties collected? Are civil contempt proceedings initiated? Are the decrees modified? Are additional compliance monitoring requirements imposed? (L) What are the reasons for the Region's/States' failure to take remedial action against permittees that violate their consent decrees? (M) To what extent has the quality of the Region's/ States' self-monitoring data improved due to DMR/QA? How is this verified? (N) What problems still need to be addressed by the Region/States to make the DMR/QA program more effective? QUANTITATIVE MEASURES (e) CONSENT DECREES Identify by name and NPDES number all permittees with active consent decrees and report their compliance status as follows:* - in compliance with decree; - in violation of decree, but remedial action taken; and - in violation of decree, no remedial action taken (list separately: major, minor; municipal, non- municipal, Federal). IN SPMS/ COMMITMENT No/No REPORTING FREQUENCY Quarterly SOURCE OF DATA Region/ State (f) I of follow-up actions on DMR/QA performance sample results: - nonrespondents; - permittees requiring corrective action. No/No Semi- annually; April 1, 1986 Oct. 1, 1986 Region ------- ENFORCEMENT; OBJECTIVE: IMPROVE COMPLIANCE WITH NPDES PERMIT REQUIREMENTS AND ENFORCEABLE SCHEDULES, WITH SPECIAL EMPHASIS ON MUNICIPAL COMPLIANCE, (pg. 30) ACTIVITIES 3. Improve Quality and Timeliness of Enforcement Responses (Cont'd) 4. Non-NPDES Enforcement \O QUALITATrVE MEASURES FOR MID-YEAR REVIEWS (0) What is involved in State/Region coopera- tion and how has it worked best? Are States participating fully? (A) Is there a trend of increased numbers of hazardous substances spills being reported and investigated? (B) Is the average quantity of spilled material increasing, decreasing, or staying the same? (C) Are administrative actions being issued for noncompliance with Spill Prevention Control and Countermeasure (SPCC) Plan requirements? QUANTITATIVE MEASURES IN SPMS/ COMMITMENT REPORTING FREQUENCY SOURCE OF DATA ------- ENFORCEMENT; OBJECTIVE: PROMOTE NATIONAL CONSISTENCY IN THE NPDES COMPLIANCE MONITORING PROGRAM, WITH SPECIAL EMPHASIS ON IMPROVING DATA MANAGEMENT AND CONDUCTING INSPECTIONS, (pg. 30) ACTIVITIES 1. Increase Use of PCS as the Primary Source of NPDES Program Data T U) o QUALITATIVE MEASURES FOR MID-YEAR REVIEWS (A) What actions are Region/ States taking to improve the quality of PCS data? (B) Have the Regions entered required data into PCS at approximately 25% per quarter? What are the Region's/ States' procedures for routinely entering and vertifying dis- charge monitoring report data for all major permittees, in particular, completed and operational P.L. 92-500 facilities? How current are the date entered? (C) Do the Region/States use the preprinted DMR form to minimize compliance tracking problems and PCS entry work- load? What is the Region doing to encourage the States to use preprinted DMRs? (D) Does the Region use PCS as the primary system for routine program management? Have all all redundant elements of local systems been terminated? QUANTITATIVE MEASURES (a) WENDB Quarterly verify Water Enforcement National Data Base (WENDB) and DMR data for completeness and accuracy in both: - NPDES States; - non-NPDES States. (b) PCS 'F1 and '$' INDICATORS Quarterly verify and enter into PCS the designator for all major permittees on final effluent limits and the designator for all major and minor P.L. 92-500 POTWs. IN SPMS/ COMMITMENT No/No REPORTING FREQUENCY Quarterly SOURCE OF DATA PCS No/No Quarterly PCS ------- ENFORCEMENT; OBJECTIVE: PROMOTE NATIONAL CONSISTENCY IN THE NPDES COMPLIANCE MONITORING PROGRAM, WITH SPECIAL EMPHASIS ON IMPROVING DATA MANAGEMENT AND CONDUCTING INSPECTIONS, (pg. 30) ACTIVITIES 1. Increase Use of PCS as the Primary Source of NPDES Program Data (Cont'd) QUALITATIVE MEASURES FOR MID-YEAR REVIEWS (E) How is the Region encouraging increased State participation in PCS? Is the Region giving priority in assistance and program grant funding to States that are direct users of PCS? Is the Region aware of any State(s) planning to move off PCS? If so, what steps is the Region taking? QUANTITATIVE MEASURES IN SPMS/ COMMITMENT REPORTING FREQUENCY SOURCE OF DATA T ------- ENFORCEMENT! OBJECTIVE: PROMOTE NATIONAL CONSISTENCY IN THE NPDES COMPLIANCE MONITORING PROGRAM, WITH SPECIAL EMPHASIS ON IMPROVING DATA MANAGEMENT AND CONDUCTING INSPECTIONS, (pg. 30) ACTIVITIES 2. Improve Effectiveness of Inspection Activities T u> 10 QUALITATIVE MEASURES FOR MID-YEAR REVIEWS (A) Do the Region/States have annual compliance inspection plans for each State? What is the quality of these plans? Discuss how these plans are used. (B) Do the Region/States prepare quarterly lists of facilities to be inspected? What are the criteria used to select facilities to be inspected? Are the inspections planned to match the specific situation at each facility? How do the Region/States determine the proper inspec- tion mix? Is the mix con- sistent with the "primary use" criteria included in the NPDES Inspection Strategy? (C) How do the Region and States use DMR/QA perfor- mance sample results for targeting compliance inspections? QUANTITATIVE MEASURES (a) INSPECTION PLANS # of Regional and State inspection plans. IN SPMS/ COMMITMENT No/OW REPORTING FREQUENCY Oct. 1, 1985 SOURCE OF DATA Region (b) MAJORS INSPECTED # of major permittees inspected at least once by EPA/States (list separately: municipal, non-municipal, federal; EPA, State). (c) INSPECTIONS # of inspect'ions (CEI or better): - major permittee inspections (list separately: municipal, non-municipal, federal; EPA, State) - minor P.L. 92-500 permittee inspections (list separately: EPA, State) - significant minor permittee inspections (list separately: municipal, non-municipal, federal; EPA, State). No/OW Quarterly PCS No/No Quarterly PCS ------- ENFORCEMENT: OBJECTIVE: PROMOTE NATIONAL CONSISTENCY IN THE NPDES COMPLIANCE MONITORING PROGRAM, WITH SPECIAL EMPHASIS ON IMPROVING DATA MANAGEMENT AND CONDUCTING INSPECTIONS, (pg. 30) ACTIVITIES 2. Improve Effectiveness of Inspection Activities (Cont'd) QUALITATIVE MEASURES FOR MID-YEAR REVIEWS (D) What mechanism is used to assure that inspection results are provided to the Region/States in a timely manner? Are the data entered into PCS only after the report has been completed and signed by the reviewer or supervisor? (E) How does the Region/state follow-up when inspection results are unsatisfactory? When RI uncover problems, does the Region/State follow-up with a more intensive inspection? (F) How do the Region's/States' inspection policies focus on the most significant violators? (G) How does the Region provide its States with advance notice of inspections? Discuss how Region and State efforts are coordinated. Discuss use of independent and joint inspections*and State file reviews to overview the State inspection program. QUANTITATIVE MEASURES IN SPMS/ COMMITMENT REPORTING FREQUENCY SOURCE OF DATA ------- ENFORCEMENT; OBJECTIVE: PROMOTE NATIONAL CONSISTENCY IN THE NPDES COMPLIANCE MONITORING PROGRAM, WITH SPECIAL EMPHASIS ON IMPROVING DATA MANAGEMENT AND CONDUCTING INSPECTIONS, (pg. 30) ACTIVITIES 2. Improve Effectiveness of Inspection Activities (Cont'd) QUALITATIVE MEASURES FOR MID-YEAR REVIEWS (H) Are all major permittees inspected by EPA or the States each year? Have the Region/ States verified that Reconnais- sance Inspections of major permittees are only done on those permittees meeting the requirements specified in the attached definition section? (I) Is the Region/State con- ducting inspections consistent with the assumptions used for the FY 1986 resource alloca- tion? Is the Region setting aside a portion of its resources to do neutral inspec- tions on minors? Discuss. QUANTITATIVE MEASURES IN SFMS/ COMMITMENT REPORTING FREQUENCY SOURCE OF DATA ------- ENFORCEMENT: OBJECTIVE: PROMOTE SOUND NPDES ENFORCEMENT PROGRAMS BASED ON UPDATED PROCEDURES AND IMPROVED COMPLIANCE WITH MILESTONES FOR TIMELY AND APPROPRIATE ENFORCEMENT RESPONSES, (pg. 30) ACTIVITIES 1. Update and Use EMS Enforcement Procedures T u> I/I QUALITATIVE MEASURES FOR MID-YEAR REVIEWS (A) Do the Region/States have revised Enforcement Management System (EMS) procedures? How is the EMS used to identify, moni- tor, and respond to noncomplying facilities? Are EMS principles implemented strictly, loosely, or not at all? (B) How do Region/States select the type of enforcement response for specific violations? (C) What kinds of formal enforce- ment actions are the Region/States using? What is the quality of these actions? (D) What kinds of informal actions (if any) are the Region/ States using in lieu of formal enforce- ment action? Are these actions documented properly? Are they effective? Do they identify chronic low-level violators? Are there provisions for escalating these responses in appropriate cases? (E) How often is it necessary for the Region to take a direct enforcement action in an NPDES State? Which States? Are the actions taken consistent with the criteria in the State over- view guidance, including prior notification and consultation? QUANTITATIVE MEASURES IN SPMS/ COMMITMENT REPORTING FREQUENCY SOURCE OF DATA ------- ENFORCEMENT: OBJECTIVE: PROMOTE SOUND NPDES ENFORCEMENT PROGRAMS BASED ON UPDATED PROCEDURES AND IMPROVED COMPLIANCE WITH MILESTONES FOR TIMELY AND APPROPRIATE ENFORCEMENT RESPONSES, (pg. 30) ACTIVITIES 2. Use Guidance Criteria and Milestones for Response to Nonocnpliance T w QUALITATIVE MEASURES FOR MID-YEAR REVIEWS (A) How do the Region and States use the exception list to establish a priority for committing conpl iance/enf oroanen t resources? (B) What problems have the Region/States been facing that would prevent them from meeting the time-lines prescribed? Which States consistently miss commitments? Does the Region provide adequate justification for facilities being on the exceptions list? (C) Does the Region use the exception list as a way of tracking State Programs? Are they reviewed quarterly along with the QNCR? Are the lists an effective management tool for the States? (D) Is there consistent application of the criteria/ milestones from State-to- State within the Region? If not, what steps is Region planning to take to improve consistency? QUANTITATIVE MEASURES (a) EXCEPTION LIST UNIVERSE Identify by name and NPDES~" number major permittees appearing on two or more con- secutive QNCRs as being in significant noncompliance (SNC) with: - final effluent limits (PEL); - construction schedules (CS); and - interim effluent limits (IEL) without being returned to compliance or addressed with a formal enforcement action (list separately: municipal, non-municipal, federal; NPDES States, non-NPDES States). (b) EXCEPTION LIST TRACKING Identify the names and total number of major permittees listed in the Exception List Universe for the previous quarter for which one of the following has occurred: - I returned to compliance; - I not yet in compliance but addressed with a formal enforcement action (list separately: municipal, non-municipal, federal; SNC with PEL, CS, IEL; NPDES States, non-NPDES States). (list separately from Excep- tion List Universe) IN SPMS/ COMMITMENT Yes/No WQ/E-9 WQ/E-11 WQ/E-13 REPORTING FREQUENCY Quarterly SOURCE OF DATA QNCR and Region/ State Data lagged one qtr Yes/SPMS- ccmposite of the two categories only WQ/E-10 WQ/E-12 WQ/E-14 Quarterly QNCR and Region/ State Data lagged one qtr ------- PRETREATMENT: OBJECTIVE: COMPLETE APPROVAL OF ALL LOCAL PRETREATMEOT PROGRAMS, INCLUDING THOSE PROGRAMS ORIGINALLY REQUIRED AND THOSE NEWLY IDENTIFIED IN FY 1985 (pg. 32) 1. Develop and Approve local Pre- txeatntent Programs QUALITATIVE MEASURES FOR MID-YEAR REVIEWS (A) What are the impedi- ments to Region's/States' local treatment program approval? (B) How well is EPA con- tract assistance (type and level) supporting development and review of local program sub- missions? (C) What criteria do Region/States use for review of local pretreat- ment programs? Are criteria consistent in technical and adminis- trative requirements? (D) Are local limit requirements applied uniformly in Region/States? (E) Are the Region's/States' review criteria abnormally re- strictive? (i.e., not-based on national policy, regs., etc.) (F) If a local program is not acceptable, how long do the Region/States allow for a resub- mission? Are any programs being approved subject to conditions? (G) What rationale do Region/States use to add/delete municipalities from the list of required local programs? QUANTITATIVE MEASURES (a) Identify the local pre- treatment programs requiring approval but not yet approved at the beginning of the fiscal year and distinguish between those newly identified in FY 85 and those previously re- quired, (list separately: non-pretreatment States, approved pretreatment States). (b) Track progress against targets for the programs approved during FY 1986 (list separately: non- pretreatment States, approved pretreatment States). (c) Identify the local pre- treatment programs approved before beginning of fiscal year (list separately: non- pretreatment States, approved pretreatment States). IN SPMS/ COMMITMENT? No/No REPORTING FREQUENCY 10/31/85 SOURCE OF DATA Region/ States Yes/SPMS WQ-12 a Quarterly Region/ States No/No 10/31/85 Region/ States ------- PRETREATMENT: OBJECTIVE: CONCENTRATE ENFORCEMENT EFFORTS ON MAINTAINING STRICT COMPLIANCE WITH ENFORCEABLE SCHEDULES, AND ON TAKING DIRECT ENFORCEMENT ACTION AGAINST INDUSTRIAL USERS CONSISTENT WITH NATIONAL PRIORITIES, (pg. 32) ACTIVITIES 1. Take Actions as Required to Obtain Compliance with PRETREATMENT Requirements T QUALITATIVE MEASURES FOR MID-YEAR REVIEWS (A) When a local program submitted for approval is not acceptable, what follow- up action is taken by the Region/State if the local program is not resutmitted in the time prescribed by the Approval Authority? (B) What are the criteria used by EPA/States to select industrial users to be inspected? What do the results of these inspections indicate? What use is being made of these results? (C) Do the Region/States place a priority on inspecting lUs that discharge to unapproved POTWs and are subject to Federal categorical standards? Are all inspections of lUs that discharge to approvedsPOTWs done as a result of a POTW pretreatment inspection which gave cause to doubt the performance of the IU? (D) How do the Region/States ensure that local pretreatment programs are fully implementing NPDES permit pretreatment requirement? QUANTITATIVE MEASURES IN SPMS/ COMMITMENT REPORTING FREQUENCY SOURCE OF DATA (a) PRETREATMENT INSPECTIONS (see also POTW pretreatment audits) # of EPA and State pretreatment WQ/E-19 inspections of: - Pretreatment POTWs - Industrial Users (IUs) that discharge to unapproved POTWs - IUs that discharge to approved POTWs (list separately: POTW, IU of an unapproved POTW, IU of an approved POTW; EPA, States). Yes(POTWs and IUs only)/SPMS Quarterly PCS (b) PRETREATMENT AOs Yes/No I of EPA ACS and State equivalent actions issued: WQ/E-20 - for POTW pretreatment violations Quarterly PCS or Region/ State ------- PRETREATMENT: OBJECTIVE: CONCENTRATE ENFORCEMENT EFFORTS ON MAINTAINING STRICT COMPLIANCE WITH ENFORCEABLE SCHEDULES, AND ON TAKING DIRECT' ENFORCEMENT ACTION AGAINST INDUSTRIAL USERS CONSISTENT WITH NATIONAL PRIORITIES, (pg. 32) ACTIVITIES 1. Take Actions as Required to Obtain Compliance with PRETREATMENT Requirements (Cont'd) T QUALITATIVE MEASURES FOR MID-YEAR REVIEWS (E) How do the Region and Stated identify and respond to industrial noncompliance with categorical pretreatment standard deadlines? (F) What is the quality of pretreatment AOs? Referrals? (G) What are the criteria the Region/States use to select pretreatment referral cases? What is the involve- ment of ORC in this selec- tion? (H) What is the level of coordination for pretreat- ment cases between the compliance section and ORC in the Region and the respective agencies in the States? If less than satisfactory, what steps is the Region taking to improve coordination? QUANTITATIVE MEASURES - for industrial user pretreatment violations (list separately: EPA, States). (c) PRETREATMENT REFERRALS f of pretreatment referrals or State equivalent actions: - civil referrals sent to HQ/DOJ/SAG; - civil referrals filed; and - criminal referrals filed in response to: - POTW non-submittal of an approvable pretreatment program. - other POTW pretreatment violations - industrial user pretreatment violations (list separately: EPA, States). IN SPMS/ COMMITMENT REPORTING FREQUENCY SOURCE OF DATA Yes/No WQ/E-21 Quarterly DOCKET System and Region/ State ------- PRETREATMENT ACTIVITIES 1. Oversee Effectivenee of Local Pre- treatment Program Im- plementation s OBJECTIVE: ENSURE THAT CONTROL AUTHORITIES FULLY IMPLEMENT SOUND LOCAL PRETREATMENT PROGRAMS (pg. 32) QUALITATIVE MEASURES FOR MID-YEAR REVIEWS (A) Have Region/States de- veloped local program in- ventories which enables the identification of the priority programs? Are the priorities set on the basis of the rela- tive size of approved local programs in terms of popu- lation and number of signifi- cant industrial users? (B) How many audits do Region/States plan to con- duct? What are the findings fron these audits? (C) Are annual report sub- missions by POTWs reviewed by the Region/State? What criteria are used for these reviews? Are approved pro- gram reviews conducted by the Region/State? (D) How well are POTWs implementing the program? For example, are POTWs de- veloping new local limits, issuing permits to indus- trial users, requesting programs to improve their effectiveness, etc.? QUANTITATIVE MEASURES (a) Track # of POTW audits in non-pretreatment States. in pretreatment States. (b) Track # of pretreatment categorical determinations made and # of removal credit applications received (non-pretreatment States, pretreatment States). IN SPMS/ COMMITMENT REPORTING FREQUENCY SOURCE OF DATA Yes/Yes Quarterly Region (Combined total of pretreatment and non-pretreatment States) WQ-12b No/No Quarterly Region/ States ------- PRETREATMENT ACTIVITIES 1. Oversee Effectiveness of Local Pre- treatment Program Im- plementation (Cont'd) OBJECTIVE: ENSURE THAT CONTROL AUTHORITIES FULLY IMPLEMENT SOUND LOCAL PRETREATMENT PROGRAMS (pg. 32) QUALITATIVE MEASURES FOR MID-YEAR REVIEWS (E) How well are local programs incorporating categorical standards? Are Region/States ex- periencing problems with evaluating baseline monitoring reports and compliance requirements? (F) What problems is the Region having with cate- gorical determinations, FDF variances, and requests for removal credits? (G) Is experience from program audits used by the Region/State to improve future local programs or train POTW staff? (H) How well are Region/States using contractor assistance (type and level) supporting implementation and helping to resolve problems? QUANTITATIVE MEASURES IN SPMS/ COMMITMENT REPORTING FREQUENCY SOURCE OF DATA ------- STATE PROGRAM APPROVAL/REVIEW/OVERSIGHT OBJECTIVE: ENSURE THAT NPDES STATES ASSUME RESPONSIBILITY FOR PRETREATMENT/ FEDERAL FACILITY PROGRAMS, AND PROMOTE FULLL NPDES PROGRAM APPROVAL (pg. 33) ACTIVITIES 1. Approve NPUES State Progran Requests *• 10 QUALITATIVE MEASURES FOR MID-YEAR REVIEWS (A) What progress is being made (State-by-State) with respect to NPDES States assuming pretreatment/ federal facilities programs? Do FY86 work plans/grant agreements have milestones for completing approval? What else is the Region doing to encourage State assumption? Is the Region considering further action in any of the States? Have the States been informed of the possibility of program withdrawal? (B) What is Region*s strategy for each State to achieve full NPDES program administration and is the FY84 strategy being carried out? QUANTITATIVE MEASURES (a) Achieve NPDES program approvals and modifications in accordance with established schedules: - Full NPDES programs; - Pretreatment program modifications; - Federal facility modifications. IN SPMS/ COMMITMENT No/OW REPORTING FREQUENCY Provide list start of FY SOURCE OF DATA Regions ------- STATE PROGRAM OBJECTIVE: REVIEW NPDES STATE PROGRAMS TO ENSURE ADEQUATE STATUTORY AND REGULATORY AUTHORITY UNDER CURRENT STATE LAWS AND REGULATIONS (pg. 33) ACTIVITIES 1. Review Approved NPDES State Statutory and Regulatory Authority. QUALITATIVE MEASURES FOR MID-YEAR REVIEWS (A) Has the Region had any difficulties in obtaining adequate documentation from the States to conduct these reviews? If so, what documents are usually needed, how are the difficulties being resolved, and how long are the delays? (B) Does the Office of Regional Counsel parti- pate in the reviews? In what way? Do they parti- cipate in the process of selecting States for review and making commit- ments? Do they follow through with their work? In a timely manner? Are priorities a problem? It so, how are conflicts resolved? (C) Does the Region have a routine mechanism for learning of changes to State laws and regulations? It so, describe the process. QUANTITATIVE MEASURES (a) Update list of NPDES Staes for which Region will assess statutory and regulatory authority in FY 86. (b) Track progress against targets for the number of NPDES States for which statutory and regulatory authority is assessed in FY 86. IN SEMS/ COMMITMENT Np/GW No/No REPORTING FREQUENCY Provide list start of FY Second and Fourth Quarters SOURCE OF DATA Region Region ------- STATE PROGRAM APPROVRL/REVIEW/OVERSICHr ACTIVITIES 1. Execute EPA/State NPDES Agree- ments *• 2. Provide Effective Oversight of Approved NPDES State Programs OBJECTIVE: EXECUTE FY 1986 EPA/STATE NPDES AGREEMENTS (CONSISTENT WITH NATIONAL POLICY AND GUIDANCE AND OVERVIEW STATE PERFORMANCE ACCORDINGLY (pg. 33) QUALITATIVE MEASURES FOR MID-YEAR REVIEWS (A) Has the Region executed NPDES agreements with all approved NPDES States? When are these agreements signed? Who participates in their development? (B) Vhat problems have arisen in the development of EPA/ State NPDES agreements? How are they resolved? Are there any particular elements of national policy and guidance on State overview that have been difficult to implement? Are there any recommendations for changing national policy or guidance? (A) To what extent has the Region impelemented the "Guidance for Oversight of NPDES Programs"? (B) Does the Region carry out a program of regularly scheduled assessments of each approved NPDES State to assure the adequacy of funding and staffing and to assure a demonstrated ability to set program QUANTITATIVE MEASURES IN SPMS/ COMMITMENT? REPORTING FREQUENCY SOURCE OF DATA ------- STATE PROGRAM APPROVAL/REyiEW/OVERSIGHr ACTIVITIES 2. Provide Effective Oversight of Approved NPDES State Programs (oont.) 9> in OBJECTIVE: EXECUTE FY 1986 EPA/STATE NPDES AGREEMENTS CONSISTENT WITH NATIONAL POLICY AND GUIDANCE AND OVERVIEW STATE PERFORMANCE ACCORDINGLY (pg. 33) QUALITATIVE MEASURES FOR MID-YEAR REVIEWS priorities and effectively implement the NPDES program? What is the frequency; who is involved; and where La it done? What is the nature and timing of followup? Does this include identifi- cation of State needs and problems, evaluation of performing and providing of technical assistance? (C) Does oversight of State permitting include an audit of permits to assess the timely issuance of high- quality permits? How is this determined by the Region? (D) Does oversight of State compliance monitoring include an assessment of the timeli- ness, completeness, and accur- acy of self-monitoring reports? How is this determined by the Region? Does the Region assess the States' reporting system on compliance status and the accuracy and accessibility of the information? Does the Region check the States compli- ance inspection activity with regard to its procedures and effectiveness? How? QUANTITATIVE MEASURES IN SPMS/ COMMITMENT? REPORTING FREQUENCY SOURCE OF DATA ------- STATE PROGRAM/APPROVAL/REVIEW/OVERSIGOT OBJECTIVE: EXECUTE FY 1986 EPA/STATE NPDES AGREEMENTS CONSISTENT WITH NATIONAL POLICY AND GUIDANCE AND OVERVIEW STATE PERFORMANCE ACCORDINGLY (pg. 33) ACTIVITIES 2. Provide Effective Oversight of Approved NPDES State Programs (cent.) T *» QUALITATIVE MEASURES FOR MID-YEAR REVIEWS (E) Does oversight of State enforcement include an assess- ment of the timeliness of the evaluation of violations and the appropriateness of initial responses* followup and escal- ation until compliance is ob- tained? Are NOVs, AOs, and judicial actions assessed for their timeliness, clarity, and enforoeability? (F) What progress is being made by the Region and States in developing and adhering to EPA/State enforcement agreements for improving compliance rates? (G) What is the nature and quality of typical oonnunica- tions between NPDES States and the Region? What steps are taken to assure continuing and effective State/EPA connunications? What is the general condition of coopera- tion between the Region and each State? How are coopera- tive arrangements established? How is State/EPA cooperation assessed and problems remedied? QUANTITATIVE MEASURES SPMS/OW COMMITMENT? REPORTING FREQUENCY SOURCE OF DATA ------- SEME PROGRA^APPRJVAL/REVIEW/OVERSIGHT OBJECTIVE: EXECUTE FY 1986 EPA/STATE NPDES AGREEMENTS CONSISTENT WITH NATIONAL POLICY AND GUIDANCE AND OVERVIEW STATE PERFORMANCE ACCORDINGLY (pg. 33) ACTIVITIES 3. Use Annual Grant Negotiations to Reinforce Performance 9> *• QUALITATIVE MEASURES FOR MID-YEAR REVIEWS QUANTITATIVE MEASURES SPMS/OW COMMITMENT? REPORTING FREQUENCY SOURCE OF DATA (A) How are §106 grants and the work planning process used to assure effective implementation of NPDES State programs? What water program areas are specific- ally addressed? Are they con- sistent with the Agency Operating Guidance? Is the Region working with the States to consolidate the work programs for all activities funded under §§106, 205(g), and 205(j)? (B) Is the Region using the per- formance-based grant approach? Describe the performance-based grant provisions employed by the Region. Does the Region find this aproach beneficial to achieving program objectives? What is working and what is not working? NOTE: Qualitative and quantitative measures of State per- formance related to specific State activities (e.g., permitting and enforcement) may be found in other sections. Those measures also contribute to providing effective NPDES State Program oversight. ------- MARINE AND ESTUARINE PROTECTION OBJECTIVE: ENSURE THAT COMMITMENTS TO THE GREAT LAKES WATER QUALITY AGREEMENT AND TO THE CHESAPEAKE BAY PLAN ARE MET (pg. 26) T *» 00 ACTIVITIES 1. Work with States to consider Great Lakes Areas of Concern and in Chesa- peake Bay Critical Areas in Developing and Revising Priority Waterbody Lists 2. Review Revised Water Quality Standards (WUS) to Determine Impact on Great Lakes and Chesa- peake Bay QUANTITATIVE MEASURES (a) I of Great Lakes Areas of Concern included as priority waterbodies. (b) # of Chesapeake Bay critical areas included as priority waterbodies. IN SPMS/ COMMITMENT? NO/NO No/No QUALITATIVE MEASURES FOR MID-YEAR REVIEWS (A) To what extent were the Great Lakes Areas of Concern and Chesapeake Bay critical areas con- sidered in the development and revision of the States' priority waterbody lists? (B) What actions did the Great Lakes National Program Office, the Chesapeake Bay liaison Office, and the Regions take to ensure that these areas have priority and that priority activities to abate problems are under- way? (A) At what stage and to what extent were Great Lakes and Chesapeake Bay impacts considered in the revision of WQS? Did the Regions conduct an evaluation of whether the modified use or criteria proposed by States would hinder meeting the objectives of the Great Lakes Water Quality Agreement or the Chesapeake Bay "Framework for Action" Plan? "Unless otherwise specified Reporting will be at the Region's Mid-year Review and the Source of Data will be the Region's Self-Evaluation. REPORTING FREQUENCY Mid-year Review* SOURCE OF DATA Region's Self- Evalua- tion ------- MARINE AND ESTUARINE PROTECTION OBJECTIVE: ENSURE THAT COMMITMENTS TO THE GREAT LAKES WATER QUALITY AGREEMENT AND TO THE CHESAPEAKE BAY PLAN ARE MET (pg. 26) ACTIVITIES 3. Assess Municipal Compliance for Con- sistency with Objec- tives of Great Lakes Water Quality Agreement and to Protect the Criti- cal Areas in Chesa- peake Bay QUALITATIVE MEASURES FOR MID-YEAR REVIEWS ^ (A) Has oorrpliance with the phosphorus require- ment improved over last year? If not, what efforts have GLNPO, and the Chesapeake Bay Liaison Office, and Regions made to increase compliance? What is hindering compliance? (B) Are certain permits targeted for special review due to Great Lakes or Chesapeake Bay concerns? On what basis? QUANTITATIVE MEASURES (a) I of Great Lakes major POTWs in compliance with 1 mg/L phosphorus requirement vs. total # of major POTWs. (b) # of Chesapeake Bay AWT POTWs funded vs. * of AWT POTWs determined to be needed. (c) % of total flow from major Great Lakes POTWs meeting the Img/L phosphorus goal or % of total flow from upper Chesapeake Bay POTWs meeting 2mg/L phosphorus goal. IN SPMS/ COMMITMENT? No/No REPORTING FREQUENCY Mid-year Review* SOURCE OF DATA Region's Self- Evalua- tion* No/No No/No ------- MARINE AND ESTUARINE PROTECTION ACTIVITIES OBJECTIVE: ENSURE THAT COMMITMENTS TO THE GREAT LAKES WATER QUALITY AGREEMENT AND TO THE CHESAPEAKE BAY PLAN ARE MET (pg. 26) QUALITATIVE MEASURES FOR MID-YEAR REVIEWS QUANTITATIVE MEASURES IN SENS/ COMMITMENT? REPORTING FREQUENCY SOURCE OF DATA 4. Imple- ment the Great Lakes and Chesa- peake Bay Monitoring Programs T (A) What efforts are GLNPO and the Chesapeake Bay Liaison Office making to ensure that the monitoring programs are being imple- mented and that resources are being used to detect emerging problems as well as for trend monitoring in priority areas? (B) What are the results of analyses of tributary monitoring, atmospheric deposition sampling, and lake surveys conducted in the Great Lakes Basin from previous years? Are reductions in loadings and other improve- ments visible? (a) # of monitoring No/No stations in operation on Chesapeake Bay's mainstem vs. I of monitoring stations planned. (b) f of fixed tributary No/No stations in operation in Great Lakes basin vs. f requested by GLNPO from States. (c) # of air monitoring No/No stations operated in Great Lakes basin vs. # requested by GLNPO from States. (d) f of fish collections No/No received by GLNPO vs. # of fish collections requested from States. Mid-year Review* Region's Self- Evalua- tion* ------- MARINE AND ESTUARINE PROTECTION OBJECTIVE: ENSURE THAT COMMITMENTS TO THE GREAT LAKES WATER QUALITY AGREEMENT AND TO THE CHESAPEAKE BAY PLAN ARE MET (pg. 26) r Ul ACTIVITIES 5. Assist States in Implementing NFS Controls in Lake Erie, Lake Ontario, Saginaw Bay, and Chesapeake Bay Basins QUALITATIVE MEASURES FOR MID-YEAR REVIEWS (A) What efforts are GLNPO, Regions, the Chesapeake Bay Liaison Office, and States making to ensure NPS imple- mentation of Agricultural BMPs (include work with other Federal agencies)? (B) What efforts are GLNPO, Chesapeake Bay Liaison Office, the Regions, and the States making to monitor implementa- tion and its results in Water Quality improvements? (C) Have the Great Lakes and Chesapeake Bay States modified their WQM plans to reflect institutional & other arrange- ments for dealing with NPS pollution? How? QUANTITATIVE MEASURES (a) # of acres in the Great Lakes Basin with BMP's in place vs. # of acres with BMP's in place at the end of FY 1985. (b) # of acres in the Chesapeake Bay basin with BMP's in place vs. # of acres with BMP's in place at the end of FY 1985. IN SPMS/ COMMITMENT? NO/NO REPORTING FREQUENCY Mid-year Review* SOURCE OF DATA Region's Self- Evalua- tion* No/No ------- MARINE AND ESTUARINE PROTECTION OBJECTIVE: ENSURE THAT COMMITMENTS TO THE GREAT LAKES MATER QUALITY AGREEMENT AND TO THE CHESAPEAKE BAY PLAN ARE MET (pg. 26) ACTIVITIES 6. Prepare Phosphorus Load Reduc- tion Plans for Lake Erie, Lake Ontario, Saginaw Bay, and Chesa- peake Bay > 7. Lnple- o, roent Study 10 Results in accordance with the Objectives of the Great Lakes Water Agreement and the Chesapeake Bay Executive Council Directives 8. Prepare Remedial Action Plans for Great Lakes Areas of Concern QUALITATIVE MEASURES FOR MID-YEAR REVIEWS (A) What efforts are GLNPO, the Chesapeake Bay Liaison Office, and the Regions/ States making to ensure schedule of appropriate activities, work plan development and interim outputs for the load reduction plans are pro- vided in a timely manner? (A) What efforts have GLNPO and the Chesapeake Bay Liaison Office made to ensure that pollution control actions are focused on priority projects? How are 106, 205(g) and 205(j) work plans focused on Great Lakes and Chesapeake Bay concerns? (A) What efforts are the GLNPO, Regions and States making to ensure appropriate schedules of activities and development of Action Plans? QUANTITATIVE, MEASURES (a) # of U.S. Great Lakes Phosphorus Reduction Plan elements being implemented vs. # planned to be underway in FY 1986. IN SPMS/ COMMITMENT? No/No REPORTING FREQUENCY Fourth Quarter SOURCE OF DATA Contact Regions (a) # of elements of Chesapeake Bay Restoration and Protection Plan being implemented vs. # planned to be underway in FY 1986. No/No Fourth Quarter Contact Region (a) # of Remedial Action Plans completed on sched- ule vs. # needed. No/Ho Fourth Quarter Contact Regions ------- MARINE AND ESTUARINE PROTECTION OBJECTIVE: ENSURE THAT COMMITMENTS TO THE GREAT LAKES WATER QUALITY AGREEMENT AND TO THE CHESAPEAKE BAY PLAN ARE MET (pg. 26) T in u> ACTIVITIES 9. Implement Connecting Channel Action Plan 10. Review Great Lakes Water guality Agreement 11. Chesapeake Bay Program Integration QUALITATIVE MEASURES FOR MID-YEAR REVIEWS (A) Are overall planning, field work, data analysis, model refinement and use, and specific yearly activities defined and completed? (A) What efforts have been undertaken by the Region to ensure a coordinated approach by all EPA and other Federal programs to meet the water quality needs of Chesapeake Bay? QUANTITATIVE MEASURES (a) f of milestones in approved work program met vs. # planned. (a) Review of Agreement completed by GLNPO/and draft report/reconroendations developed. IN SPMS/ COMMITMENT? No/No REPORTING FREQUENCY Mid-year Evaluation No/No First Quarter SOURCE OF DATA Region* Self- Evalua- tion Contact Region ------- MARINE AND ESTUARINE PROTECTION OBJECTIVE: DEVELOP AND IMPLEMENT PROGRAMS FOR PUGET SOUND, NARRAGANSETT BAY, BUZZARDS BAY, AND LONG ISLAND SOUND (pg. 26) T ACTIVITIES 1. Develop Marine & Estuarine Protection programs for Puget Sound, Narragansett Bay, Buzzards Bay, and Long Island Sound, and other estuaries as appropriate QUALITATIVE MEASURES FOR MID-YEAR REVIEWS (A) What efforts have the States/Regions made to ensure that compre- hensive programs are being developed, inclu- ding problem identifica- tion, pollutant load quantification, and assessment of system impacts, for each of these major estuarine areas? (B) What efforts have the States made to use generic guidance in the implementation of approved work plans for estuarine studies? (C) What efforts have States/Regions made to implement the approved FY 1985 work plans? QUANTITATIVE MEASURES (a) # of management struc- tures in place and operational (b) # of citizens advisory groups and technical advisory groups operational (c) # of data management systems operational (d) # of technical reports completed (e) # of draft management recommendations completed for review IN SPMS/ COMMITMENT? No/No No/No NO/NO No/No No/No REPORTING FREQUENCY Mid-year Review* SOURCE OF DATA Region's Self- Evalua- tion* ------- MARINE AND ESTUARINE PROTECTION OBJECTIVE: EXPEDITE S301(h) DECISIONS AND PERMIT ISSUANCE (pg. 27) ACTIVITIES 1. Review S301(h) Applications and Issue Permits T Ul in QUALITATIVE MEASURES FOR MID-YEAR REVIEWS (A) Was all available information considered in evaluating applications? (B) Were decisions clearly and completely documented? (C) Were all criteria evalua- ted and applied consistently among Region's applications? (D) Were dischargers with the greatest potential for adverse impacts evaluated on a priority basis? (E) How quickly are final decisions implemented through permit revisions? (F) Do permits consistently assure that the monitoring provisions of $301(h) decisions are transformed into specific enforceable requirements for use in assessing ongoing compliance with the §301(h) criteria? QUANTITATIVE MEASURES (a) t of complete applica- tions (b) # of intents to revise (c) # of withdrawals (d) # of initial decisions (e) f of final decisions (f) # of permits issued reflecting decisions (g) # of approved/successful monitoring programs in opera- tion IN SPMS/ COMMITMENT? Yes/No WQ-20 Yes/No WQ-20 Yes/No WQ-20 Yes/SBIS WQ-19 No/No Yes/SEMS WQ-19 No/No REPORTING FREQUENCY Quarterly Mid-year Review SOURCE OF DATA Contact Regions Quarterly Quarterly Quarterly Mid-year Review Quarterly Contact Regions Contact Regions Contact Regions Region's Self- Evalua- tion Contact Regions Region's Self- Evalua- tion ------- UNDERGROUND INJECTION CONTROL PROGRAM: OBJECTIVE: PROMOTE UIC DELEGATION AND MANAGE PROGRAM IN NON-DELEGATED STATES (pg. 16-17) ACTIVyriES 1. Oversee Primacy State Programs T in QUALITATIVE MEASURES FOR MID-YEAR REVIEWS • (A) What types of problems are delegated States encountering? (B) What types of assistance are States requesting? (C) How does Region exercise effective overview of delegated programs? (D) Are States carrying out their programs as approved? QUANTITATIVE MEASURES (a) Report, for information only/ the # of new State UIC primacy programs approved and the total t of injection wells covered under the approved programs. (b) Track, by well class, progress against targets for UIC permit determina- tions made by primacy States for new and exist- ing facilities for (1) Class I wells, and (2) Class II, III, and V wells (if applicable) during FY 1986. (c) Track, against targets, the # of existing Class II well record files reviewed during FY 1986. (d) Track, against targets, the # of Class II wells for which mechanical integrity tests were performed by primacy States in FY 1986. (e) Report, by State, the % of Class II wells for which mechanical integrity tests were witnessed during FY 1986. IN SEMS/ COMMITMENT? No/No REPORTING FREQUENCY SOURCE OF DATA Yes/SPMS DW-2 DW-3 Yes/SPMS DW-4 Yes/SPMS DW-5 No/No Quarterly HQ FURS Qrtrly., data lag of 1 qrtr. Region/ State Report Qrtrly., data lag of 1 qrtr. Qrtrly., data lag of 1 qrtr. Qrtrly., data lag of 1 qrtr. Region/ State Report Region/ State Report Region/ State Report ------- UNDERGROUND INJECTION CONTROL PROGRAM; OBJECTIVE: PROMOTE UIC DELEGATION AND MANAGE PROGRAM IN NON-DELEGATED STATES (pgs. 16-17) ACTIVITIES 1. Oversee Primacy State Progr* QUALITATIVE MEASURES FOR MID-YEAR REVIEWS (conf) (E) By State, what is the status of the assessment of Class V wells. (F) Are States enforcing signif iciant violations effectively? in VJ QUANTITATIVE MEASURES (f) Report, by State, for FY 1986 the f of field inspections conducted. (g) Report, by State, for FY 1986 the I of Class V wells assessed. (h) Track, by Region, for primacy States the number and percent of major wells with permit or rule requirements. (i) Identify, by Region, the number of major wells with permit or rule violations as of June 30, 1985. (j) Trackr by Region, against targets, the number of major wells in the above universe of violation which have cone back into compliance or have had formal enforcement actions taken against them. (k) Identify, by Region, the number of major wells reporting new violations. IN SFMS/ COMMITMENT? Yes/SPMS DW/E-8 No/No Yes/No DW/E-3 Yes/No DW/E-4 Yes/SEMS DW/E-5 Yes/No DW/E-6 REPORTING FREQUENCY Qrtrly., data lag of 1 qrtr. Annual SOURCE OF DATA Region/ State Report Annual Report Qrtrly., data lag of 1 qrtr. August 30, 1985 Qrtrly. Nonccm- pliance Report State Report Qrtrly., data lag of 1 qrtr. Qrtrly., data lag of 1 qrtr. Qrtrly. Noncom- pliance Report Qrtrly. Noncom- pliance Report ------- UNDERGROUND INJECTION CONTROL PROGRAM; OBJECTIVE: PROMOTE UIC DELEGATION AND MANAGE PROGRAM IN NON-DELEGATED STATES (pgs. 16-17) T in 00 ACTIVITIES 1. Oversee Primacy State Programs (cent1) 2. Imple- ment UIC in Non-Primacy States and on Indian Lands QUALITATIVE MEASURES FOR MID-YEAR REVIEWS (A) Does the Region have the appropriate skill mix for direct implementation? (B) Is program (inventory, reports, compliance) up to date? If not, explain. (C) Does the Region have a plan to eliminate permit backlogs (if any) or to improve processing time (if applicable) to prevent delays? QUANTITATIVE MEASURES (1) Track, by Region, the number of major wells identified above that have returned to compliance or have had formal enforcement actions taken against them. (a) Track, by Class, against targets, the # of permit determinations made to new and existing facilities for (1) Class I wells and (2) Class II, III, and V wells (if applicable) by EPA during FY 1986. (b) Track, by class, against targets, the average elapsed time (in days) for permit determinations. IN SPMS/ COMMITMENT? Yes/No DW/E-7 REPORTING FREQUENCY Qrtrly., data lag of 1 qrtr. SOURCE OF DATA Qrtrly. Noncom- pliance Report Yes/SPMS Dtf-2 DW-3 Qrtrly. Regional Report No/No Qrtrly. Regional Report ------- UNDERGROUND INJECTION CONTROL PROGRAM; OBJECTIVE: PROMOTE UIC DELEGATION AND MANAGE PROGRAM IN NON-DELEGATED STATES (pgs. 16-17) ACTIVITIES 2. imple- ment UIC in Non-Primacy States and on Indian Lands (cont1) QUALITATIVE MEASURES FOR MID-YEAR REVIEWS T (D) Is Region carrying out programs as submitted? (E) By State, what is the status of the assessment of Class V wells. (F) What is Region's approach for use of formal and in- formal enforcement actions? QUANTITATIVE MEASURES (c) Track, against targets, the # of existing Class II well records reviewed by EPA in FY 1986. (d) Track, against targets, the # of Class II wells for which mechanical integrity tests were performed by operators and verified by EPA during FY 1986. (e) Report, by State, the # of mechanical integrity tests witnessed by EPA in FY 1986. (f) Track, by Region, against targets, the # of field in- spections conducted in FY 1986. (g) Report, by State, the # of Class V wells assessed by EPA in FY 1986. IN SPMS/ COMMITMENT? Yes/SPMS DW-4 Yes/SPMS DW-5 No/No Yes/SPMS DW/E-8 No/No REPORTING FREQUENCY Qrtrly. Qrtrly. Qrtrly. SOURCE OF DATA Regional Report Regional Report Regional Report Qrtrly., Regional data lag Report of 1 quarter 4th qrtr. Regional Report ------- UNDERGROUND INJECTION CONTROL PROGRAM; OBJECTIVE: PROMOTE UIC DELEGATION AND MANAGE PROGRAM IN NON-DELEGATED STATES (pgs. 16-17) ACTIVITIES 2. Imple- ment UIC in Non-Primacy States and on Indian Lands (cont1) QUALITATIVE MEASURES FOR MID-YEAR REVIEWS (G) Have there been any en- forcement problems. How were they handled? ON o QUANTITATIVE MEASURES (h)Track, by Region, in direct implementation States, the nunber and percent of major wells in violation of permit or rule. (i) Identify, by Region, the number of major wells with permit or rule violations as of June 30, 1985. (j) Track, by Region, against targets, the number of major wells in the above, universe with violations which have cone back into compliance or have had formal enforcement actions taken against them. (k) Identify, by Region, the number of major wells reporting new violations. (1) Track, by Region, the number of major wells identified above that have returned to compliance or have had formal enforcement actions against them. IN SPMS/ COMMITMENT? Yes/No DW/E-3 REPORTING FREQUENCY Qrtrly. , data lag of 1 qrtr. SOURCE OF DATA Qrtrly. Non-com- pliance Report Yes/No DW/E-4 Yes/No DW/E-5 Yes/No DW/E-6 Yes/No CW/E-7 August 30, 1985 Qrtrly., data lag of 1 qrtr. Qrtrly., data lag of 1 qrtr. Qrtrly., data lag of 1 qrtr. Regional Report Qrtrly. Non-com- pliance Report Qrtrly. Non-com- pliance Report Qrtrly. Non-ccm- pliance Report ------- UNDERGROUND INJECTION CONTROL PROGRAM: OBJECTIVE: PROMOTE UIC DELEGATION AND MANAGE PROGRAM IN NON-DELEGATED STATES (pgs. 16-17) ACTIVITIES 3* Protect Aquifers that are Sole or Principal Sources of Drinking Water QUALITATIVE MEASURES FOR MID-YEAR REVIEWS (A) Assess the value of project reviews. (B) To what extent are significant problems identified? (C) What kind of remedial action has the Region tried to obtain. (D) How successful was the Region in getting remedial action? QUANTITATIVE MEASURES (a) For sole source aquifer petitions, report the # of: o Petitions received; o Reviews initiated; o Reviews completed; and o Aquifers designated. (b) Report the # of Federally assisted activities (projects) reviewed in designated sole source aquifer areas. IN SEMS/ COMMITMENT? No/No REPORTING FREQUENCY Fourth Quarter SOURCE OF DATA Regional Report No/No Fourth Quarter Regional Report ------- PUBLIC WATER SYSTEM SUPERVISION PROGRAM OBJECTIVE: IMPROVE PROGRAM MANAGEMENT (pgs 12-15) to ACTIVITIES 1. Effec- tively Manage the FUSS Program 2. Effec- tively Man- age the PtfSS Program in Non-primacy States and on Indian Lands 3. Delegate the PWSS Program 4. Prepare for Implementation of the Revised Drinking Water Regulations QUALITATIVE MEASURES FOR MID-YEAR REVIEWS (A) How well does Region track grant usage by the States? (B) Can Region document actual State use of grant funds? (A) Does Region use funds as planned? (B) Can specific benefits be attributed to fund utilization? (A) Has the Region worked diligently with States to move them toward primacy? (A) Has the Region worked with each State to develop legal authorities and analytic capability to begin regulating volatile organic' chemicals? QUANTITATIVE MEASURES IN SPMS/ .COMMITMENT? REPORTING FREQUENCY SOURCE OF DATA (a) How much money has been obligated? No/No Q 2 & 4 Regional Report ------- PUBLIC WATER SYSTEM SUPERVISION PROGRAM OBJECTIVE: IMPROVE PROGRAM MANAGEMENT (pgs 12-15) ACTIVITIES 5. Improve Conpliance with the NIPDWR QUALITATIVE MEASURES FOR MID-YEAR REVIEWS (A) Has each State reviewed sand/or revised its compliance strategy for dealing with non-compliant systems? (B) Has the Region provid- ed guidance to States on compliance strategies and setting targets for measurable compliance improvements? (C) How did the States categorize non-community systems into priority groups to target use of their resources. Have the targetted resources been used for the highest priority groups? (D) Has the Region worked with the States to target litigation actions in the most reasonable manner? Has the Region provided assistance to the States in any such actions. QUANTITATIVE MEASURES (a) Report the number of states with compliance strategies. IN SPMS/ COMMITMENT? No/No REPORTING FREQUENCY Q 2 SOURCE OF DATA Regional Reports (b) Report the numbers of civil cases referred, civil cases filed, and criminal cases filed against community water systems systems which violated a microbiological, turbidity or trihalcmethane, MCL or monitoring/reporting (M/R) requirement. (Report the three categories separately by state.) No/No Q 1,2,3,4 (Data is lagged 2 quarters) FRDS and Regional Reports ------- PUBLIC WATER SYSTEM SUPERVISION PROGRAM OBJECTIVE: IMPROVE PROGRAM MANAGEMENT (pgs 12-15) ACTIVITIES 5. Improve Compliance with the NIPDWR (cont.) T QUALITATIVE MEASURES FOR MID-YEAR REVIEWS (E) Has the Region reviewed State files of non-compliant systems to assure that enforcement actions have been timely and appropriate? Has the Region taken any federal action because of a State's failure to act? (F) How well did each State's compliance rates for FY 85 agree with the targets contained in the FY 85 grant agreements? QUANTITATIVE.MEASURES (c) Report the number of States which have documented their approach to, or concept of, timely and appropriate enforcement. IN SIMS/ COMMITMENT? No/No REPORTING FREQUENCY Q 2 SOURCE OF DATA Regional Report (d) Report, against targets, Yes/Yes for primacy and non-primacy DW/E-1 states, the # and % of com- munity water systems with persistent MCL and M/R vio- lations of the microbiological turbidity, and trihalomethane requirements. (Report separ- ately for MCL & M/R and for each contaminant.) (e) Report, against targets, No/No for primacy and non-primacy states the # and % of community water systems in full compliance (i.e., with no MCL and M/R vio- lations of the microbiological, turbidity, and trihalcmethane requirements during the 12 mos of the reporting period). (Report separately for MCL & M/R and for each contaminant.) Q 1,2,3,4 (Data is lagged 2 quarters) Q 1,2,3,4 (Data is lagged 2 quarters) FRDS FRD3 ------- PUBLIC WATER SYSTEM SUPERVISION PROGRAM OBJECTIVE: IMPROVE PROGRAM MANAGEMENT (pgs 12-15) ACTIVITIES QUALITATIVE MEASURES FOR MID-YEAR REVIEWS QUANTITATIVE MEASURES IN SPMS/ COMMITMENT? REPORTING FREQUENCY SOURCE OF DATA 5. Improve Compliance with the NIPDWR (cont.) T o* V/l (G) Identify population affected by persistent violations of drinking water requirements. (H) Have the States con- ducted surveys of ccrarunity water systems to either prevent, or correct, non- compliance• (I) Has the Region under- taken data verification activity for each State? What have results of com- pleted studies shown about report integrity? Have the States made adjust- ments to their data management system to address any problems discovered during the verification? (f) Report the popula- Yes/No tion served by community DW-1 systems with persistent MCL and M/R violations of the microbiological, tur- bidity, and trihalcmethane requirements. (Report separately for MCL & M/R and for each contaminant.) (g) Report the number of No/No states which have developed state inspection/sanitary survey policies. (h) Report separately, against Yes/Yes targets, the numbers of com- DW/E-2 munity water systems which have received a routine, prescheduled sanitary survey. (i) Report the number of data No/No verifications completed. Q 2 (Data is lagged 2 quarters) FRDS Q 2 Q 1,2,3,4 (Data is lagged 2 quarters) Q 2 Regional Report Regional Reports Regional Report ------- GROUND-WATER PROTECTION OBJECTIVE: State Ground-Water Program Support Relative to the Ground-Water Protection Strategy (p.17) T ACTIVITIES 1. Implement Sec.106 Grant program for ground-water in accordance with guidelines and FY 1986 budget alloca- tions, monitor State programs, conduct mid- year reviews, and assist States with pro- gram management problems. QUALITATIVE MEASURES MID-YEAR REVIEWS (A) To what extent have the guidelines been reflected in administration of the program? (B) How are the ground-water grants coordinated with W.Q., UIC, Waste Manage- ment, FIFRA and TSCA grant process? (C) To what extent have the States developed consolidated ground- water program plans? (D) How well does the Region track grants awarded to the States? (E) Do the States have an effective strategy for managing awarded grants and what is it? (F) Can specific benefits be attributed to EPA funded State programs and what are they? QUANTITATIVE MEASURES (a) Number of grants awarded to States and territories by December 30.** In SPMS/OW COMMITMENT? No/OW REPORTING FREQUENCY January 31, June 30,* September 30* (b) Number of State briefings, workshops, mid-year assessments, (documented and provided to appropriate parties), follow-up mid-year reviews, and meetings conducted with States. (c) Number of States submitting consolidated plans. No/No January 31, June 30, September 30 SOURCE OF DATA 106 work prog/Reg. visits, regional records. Regional records. No/OW January 31, June 30,* September 30* Regional records. *Reporting for these dates is not required if all grants are awarded by December 30. **In establising Regional commitments, the existence of State legislative barriers to acceptance of grants will be taken into consideration. ------- GROUND-WATER PROTECTION OBJECTIVE: Manage Internal Coordinating Committee Relative to the Ground-Water Protection Strategy (p.19) ACTIVITIES 2. Provide support & assistance to coord- inating committees which will engage in specific substan- tive review affect- ing all Regional programs impacting ground water and ensure a rational and consistent approach to Regional ground- water protection efforts and programs. QUALITATIVE MEASURES MID-YEAR REVIEWS (A) Has the coordinating committee and/or the Regional Office of Ground- Water been engaged in specific substantive reviews of those Regional programs impacting ground-water. (B) How has the coordinating committee directed or redirected resources to improve the Region's ground- water program? QUANTITATIVE MEASURES (a) The number of times committee meets. In SEMS/OW COMMITMENT? No/No (b) The number of topics impacting on ground-water management covered. No/No REPORTING FREQUENCY January 31, June 30, September 30 January 31, June 30, September 30 SOURCE OF DATA Reg ional records. Regional records. ------- GROUND-WRTER PROTECTION OBJECTIVE: Develop Coordinated Ground-Water Work Plans to Implement the Ground-Water Protection Strategy (p.18) ACTIVITIES 3. Develop regional work plan or compar- able management mechanism. T 8 QUALITATIVE MEASURES MID-YEAR REVIEWS (A) To what degree do the plans reflect actions affecting ground water. (B) The what degree do the plans provide a doable managerial tool to effectively track progress and provide accountability towards completing projected outputs. (C) To what degree is the Regional Ground-Water Work Plan used to integrate and facilitate ground-water related programs and efforts throughout the Regions. QUANTITATIVE MEASURES (a) The number of programs participating. (b) The number of items in the work plan which reflect national priorities. (c) The number of items in the work plan which reflect Regional priorities. In SPMS/OW COMMITMENT? No/No No/No No/Ho REPORTING FREQUENCY January 31+ June 30, September 30 January 31+ June 30, September 30 January 31+ June 30, September 30 SOURCE OF DATA Regional records. Regional records. Regional records. +Data for these quantitative measures must be reported only once—on the date which follows most closely completion of the work plan. ------- WATER QUALITY STANDARDS, PLANNING, AND ASSESSMENT; OBJECTIVE: REDUCE THE PERCENT OF STREAM MILES, LAKE ACRES, ESTUARY SQUARE MILES, COASTAL MILES AND GREAT LAKES SHORE MILES NOT SUPPORTING DESIGNATED USES (p. 25) ACTIVITIES 1. Reduce the Percentage of Stream Miles, Lake Acres, Estuary Square Miles, Coastal Miles and Great Lakes Shore Miles not Supporting Designated uses o* \o QUALITATIVE MEASURES FOR MID-YEAR REVIEWS (A) How are control priorities determined by the States and is water quality a driving factor? Do they have their problem areas well identified, i.e., priority waterbody lists? Does the Region concur with the State lists? Do they know what needs to be done to resolve problems faced by each priority waterbody strategy? How well are they implementing the needed actions identified above? Are resources targeted at priority water- bodies? (B) What are the impediments to achieving environmental results? QUANTITATIVE MEASURES (a) List priority waterbodies by State. IN SPMS/ COMMITMENTS NO/NO (b) Identify the number of stream miles, lake acres, estuary square miles, coastal miles, and Great Lakes shore miles in each Region, the number assessed and the numbers supporting/ partially supporting/ and not supporting designated uses as reported in the FY 1986 305(b) report. (c) Provide a list of those stream segments partially or not supporting designated uses, and threatened waters. Indicate those waters still requiring TMDLs/WLAs. List problem parameters and source, such as municipal and industrial point source or type or NPS, for each segment, and identify those that are priority waterbodies. Briefly describe state and Regional actions planned for these waters. Yes/No WQ-21 REPORTING FREQUENCY First/ Third Quarters Third Quarter SOURCE OF DATA 305 (b) Reports, 106, 205(j) Work Programs 305 (b) Reports No/No Mid-year Review 305(b) Reports ------- WATER QUALITY STANDARDS, PLANNING, AND ASSESSMENT; OBJECTIVE: INCORPORATE PROVISIONS OF WATER QUALITY STANDARDS REGULATIONS (NOV.8, 1983) INTO STATE WATER QUALITY STANDARDS FDR TOXIC POLLUTANTS (p. 25) ACTIVITIES 1. Undertake Use Attain- ability Analyses and Site Specific Criteria Actions and Inclusion of Toxic Criteria into standards 2. Work with States to Identify Problems and to Ensure Effective Implement— ation of the WQS Regulation QUALITATIVE MEASURES FOR MID-YEAR REVIEWS (A) Are the States developing use attain- ability assessments for reaches designated less than fishable/swimmable? Are the States identi- fying water bodies with toxics problems? Are narrative or numerical criteria being adopted for toxics of concern? If numeric, are the States using EPA or EPA modified criteria? (A) Are the States making any significant revisions, additions or modifications to State WQS or implementation policies? Are the States encountering problems in defining areas that may not attain uses upon implement- ation of technology based permits or in applying existing program guidance? QUANTITATIVE MEASURES (a) # of WQS reviewed. (b) # of use attain- ability assessments. (c) Track, by Region, against semiannual tar- gets, the number of States which incorporate new or revised numeric and/or narrative criteria for toxic pollutants into state Water Quality Standards and which are approved by the Regional Office. (d) f and % of stream segments in Region designated less than fishable and swimnable. (e) f of promulgation actions, approvals, and disapprovals. IN SPMS/ COMMITMENTS NO/NO NO/NO Y6S/SPMS WQ-26 REPORTING FREQUENCY Mid-year Review Mid-year Review Second/Fourth Quarters SOURCE OF DATA 106, 205(j) Work Pro- grams State WQS No/No Mid-year Review No/Ho Mid-year Review 106, 205(j) Work Pro- grams Stan- dards Review Process ------- WATER QUALITY STANDARDS, PLANNING, AND ASSESSMENT; ACTIVITIES 1. Imple- ment the Guidance for State Water Monitoring and Waste- load Allo- cation Programs OBJECTIVE: IMPROVE USE OF MONITORING DATA IN MANAGING FOR ENVIRONMENTAL RESULTS (p. 24) QUANTITATIVE MEASURES QUALITATIVE MEASURES FDR MID-YEAR REVIEWS IN SPMS/ COMMITMENTS REPORTING FREQUENCY (A) How well are the States beginning to implement the Water Monitoring Guidance (as revised in FY85)? Did States provide requested checklist information? Have the States developed adequate monitoring strategies? Are they encountering any pro- blems in implementing specific elements of the guidance? (B) Have States included biological and toxic monitoring activities in their ambient monitoring programs? How do the States/ Region determine the need for biological and toxic ambient monitoring? (C) What is the status of quality assurance/ quality control (QA/QC) procedures in each State? Are the States implementing grant requirements for OA plans? Are the States developing data quality objectives? (a) f of intensive No/No surveys completed, and # of fixed stations operated on a regular basis, for water quality assessments statewide. (b) f of intensive sur- No/No veys conducted, including biological field surveys, for water quality based controls. (c) # of QA Program No/No Plans and # of Work/QA Project Plans completed. Second/ Fourth Quarters Second/ Fourth Quarters Second/ Fourth Quarters SOURCE OF DATA 106, 205(j) Work Pro- grams 106, 205(j) Work Pro- grams 106, 205(j) Work Pro- grams ------- WATER QUALITY STANDARDS, PLANNING, AND ASSESSMENT; OBJECTIVE: IMPROVE THE USE OF MONITORING DATA IN MANAGING FOR ENVIRONMENTAL RESULTS (p. 24) ACTIVITIES 1. Imple- ment the Guidance for State Water Monitoring and Waste- load Allo- cation Programs (cont.) :> ro QUALITATIVE MEASURES FOR MID-YEAR REVIEWS (D) Are the states applying an appropriate balance of resources between monitoring to support assessments vs. monitoring to support development of WQ-based controls? What are the dollar and resource figures? (E) Have States adequately planned their monitoring activities, and were 305(b) Reports and identified priority waterbodies considered? (F) Are States providing appropriate data to STORET on a timely basis, as dis- cussed in the Guidance? Are the states working to improve data management? (G) Did the State undertake any monitoring and/or screen- ing programs to identify new or emerging problems? (H) In the waters states identified as "partially supporting" or "not supporting designated uses": did the state conduct chemical and/or bio- logical monitoring to confirm and/or characterize pollution problems? QUANTITATIVE MEASURES IN SPMS/ COMMITMENTS REPORTING FREQUENCY SOURCE OF DATA ------- WftlER QUALITY STANDARDS, PLANNING, AND ASSESSMENT; ACTIVITIES 2. Improve State 305(b) Reports OBJECTIVE: IMPROVE USE OF MONITORING DATA IN MANAGING FOR ENVIRONMENTAL RESULTS (p. 24) QUANTITATIVE MEASURES T QUALITATIVE MEASURES FOR MID-YEAR REVIEWS IN SPMS/ COMMITMENTS REPORTING FREQUENCY (A) To what extent do the 305(b) reports include: 0 the water quality meas- ures developed through STEP? 0 a list of segments not fully supporting design- ated uses and associated information? 0 information on toxics? 0 information on nonpoint sources (including ASIWPCA assessment)? 0 Clean lakes and ground water information? 0 are fully responsive to national guidance? (B) Is the water quality information in the reports used to establish priorities for other programs, such as monitoring, permits, or con- struction grants as called for in Part 130 regulations? (C) Are the reports in- cluded specifically as a commitment in the 106/205(j) work programs and/or State/ EPA agreements? (a) f of State 305(b) No/No reports which are timely and fully responsive to national guidance (b) * of State 305(b) No/No reports used for making program decisions by the Region and State Third Quarter Third Quarter SOURCE OF DMA State 305(b) Reports State 305(b) Reports ------- WATER QUALITY STANDARDS, PLANNING, AND ASSESSMENT: OBJECTIVE: IMPROVE THE EFFECTIVENESS OF MONITORING ACTIVITIES BY FOCUSING ON IMPORTANT WATER QUALITY PROBLEMS (p. 24) ACTIVITIES 1. Bnple- roent Bio- monitoring Program T 2. Bnple- ment National Studies of Toxic Pollutants QUALITATIVE MEASURES FOR MID-YEAR REVIEWS (A) To what extent has the Region established a base capability to conduct biononitoring, including bioassays and field surveys? Is the number of species cul- tured and tested adequate? (B) To what extent have the States been able to improve their bicmonitor- ing capability? To what extent have the States begun to use their bicmonitoring capability? To what extent have the States begun to use bio- monitoring as part of an integrated approach for controlling toxic pollutants? (A) Has the Region encountered any problems in implementing the bioaccumulative pollutant study? QUANTITATIVE MEASURES (a) # of flow-through and static bioassays for setting WQ-based controls. (b) # of.field surveys for setting WQ-based controls and for ambient assessments. IN SPMS/ COMMITMENTS NO/NO NO/NO REPORTING FREQUENCY Second/ Fourth Quarters Second/ Fourth Quarters (a) ft of sampling plans No/No prepared. (b) Track, by Region, the No/No percentage of sampling workplan ccmmitments met for bioaccumulative pol- lutant studies. Mid-year Review Fourth Quarter SOURCE OF DATA 106, 205(j) Work Programs 106, 205(j) Work Programs 106, 205(j) Work Programs 106, 205(j) Work Programs ------- WATER QUALITY STANDARDS, FLAWING, AND ASSESSMENT; OBJEiCTIVE: IMPROVE THE EFFECTIVENESS OP MONITORING ACTIVITIES BY FOCUSING ON IMPORTANT WATER QUALITY PROBLEMS (p.24) ACTIVITIES 3 • Implement Regulatory Monitoring Programs and Develop TMDLS/WLAS •r -*J Ul QUALITATIVE MEASURES FOR MID-YEAR REVIEWS (A) To what extent are the States developing WQ-based controls? is the number of WQ-based controls being developed increasing or decreasing and why? Is the mix between conventional and toxics work appropriate? Are they conducting TMDLs/ WLAs solely in priority waterbodies or also in other areas? How are these funded? Are States following the EPA policy for developing toxics WLA? (B) Is the process for conducting and approving TMDLs/WLAs working well? Did the monitoring program provide adequate support to making important WQ-based regulatory decisions? Did the States use EPA recommended methodology for relating WQ conditions to effluent limitations? Is the tech- nical defensibiiity of the TMDLs/WLAs improving? Is the public involved? Have the States provided an implementation schedule? (C) What issues have developed in the TMDL/ WLA process/and how is the Region resolving these? QUANTITATIVE MEASURES (a) Identify, by Region, fran the list of waters not fully supporting designated uses, the number of waterbodies needing WQ-based controls and the number of TMDLs needed in these waters. (b) * Of TMDLS/WLAS conducted for conven- tional pollutants. (c) t Of TMDLS/WLAS with pollutant specific toxic limits, and # with biomonitoring- derived toxic limits. (d) Track, by Region, the number of TMDLs initiated in these waters. (e) Track, by Region, against quarterly tar- gets, the number of TMDLs for toxics and number of TMDLS for conventionals completed in waters not tully supporting designated uses. IN SPMS/ COMMITMENTS Yes/No WQ-24 REPORTING FREQUENCY 10/15/85 NO/NO NO/NO NO/NO Yes/SPMS WQ-25 Third/ Fourth Quarters Third/ Fourth Quarters Third/ Fourth Quarters Each Quarter SOURCE OF DATA 106, 205(j) Work Pro- grams 106, 205(j) Work Pro- grams 106, 205(j) Work Pro- grams 106, 205(j) Work Pro- grams 106, 205(j) Work Pro- grams ------- WATER QUALITY STANDARDS, PLANNING, AND ASSESSMENT: OBJECTIVE: IMPROVE WATER QUALITY GRANTS MANAGEMENT (pp. 8-11, 25) ACTIVITIES 1. Update WQM Plans 2. Use WQM Plans to Ensure Con- sistency 3. Manage State Grants Effectively QUALITATIVE MEASURES FOR MID-YEAR REVIEWS (A) Have the Regions approved WQM plan updates? How effective is the process? If a State prepares no plan updates, what action is the Region taking? How does the Region assist States in de- termining needed updates? (A) How is the Region en- suring that States use the WQM plan to make consist- ency determinations regarding permits and construction grants? Give examples. (A) How are the elements of the 205(j) and 106 work programs coordinated? (B) How are 205(j) funded outputs used at the State/ Regional levels to make WQM decisions? Give examples. QUANTITATIVE MEASURES (a) t and list of WQM plan elements updated. IN SPMS/ COMMITMENTS NO/NO REPORTING FREQUENCY Mid-year Review (C) What procedures are used to negotiate, track and evaluate work program commitments and State per- formance? Any problems encountered in applying these procedures? What sanctions or other efforts do you use to correct deficiencies? Give examples of efforts to correct deficiencies in State performance. (a) I of consistency reviews conducted by Region for permits and construction grants. (a) List major 205(j) projects/activities for each state and indicate which of these will be included in , future WQM plan updates. (b) To date, what percent of 106 and 205(j) work program ociuuitments by program element has each State met? No/fco Mid-year Review No/No Mid-year Review No/No Mid-year Review SOURCE OF DATA 106, 205(j) Work Pro- grams 106, 205(j) Work Pro- grams 106, 205(j) Work Pro- grams 106, 205(j) Work Pro- grams ------- WATER QUALITY STANDARDS, PLANNING, AND ASSESSMENT; OBJECTIVE: IMPROVE WATER QUALITY GRANTS MANAGEMENT (pp. 8-11, 25) ACTIVITIES 3. Manage State Grants Effectively (cont.) T QUALITATrVE MEASURES FOR MID-YEAR REVIEWS (D) What steps are being taken to assure that States meet 106 Level of Effort (DOE) requirements, including me- thods for assuring that State accounting systems are ade- quate and reported expendi- tures are accurate? Have 106 and 205(g) grant awards met LOE requirements; if not is the Region taking steps to rectify the problem, i.e. recovering grant funds? (E) Are States using priority waterbody lists to allocate resources to address critical water quality problem areas? How is the Region using priority waterbody lists to negotiate States grants and provide oversight of State programs? QUANTITATIVE MEASURES In SFMS/ COMMITMENT? REPORTING FREQUENCY SOURCE OF DMA 106, 205(j) Work Pro- grams 106, 205(j) Work Pro- grams ------- WATER QUALITY STANDARDS, PLANNING, AND ASSESSMENT; OBJECTIVE: IMPLEMENT NPS POLICY AND STRATEGY (p. 25-26) ACTIVITIES 1. Develop List of Waterbodies impacted by NPS and implement NPS Control Programs T •>! 00 QUALITATIVE MEASURES TOR MID-YEAR REVIEWS (A) How is this list being used to direct control decisions? (B) What is the status of NPS programs, by State broken down by NPS category, indicating whether the effort is program develop- ment or implementation? What is the Region doing to further NPS program development? (C) What is the schedule for implementing NPS con- trols, by State? What is the source(s) of funds? (D) Discuss the Regional/ State approach to imple- menting the Agency NPS strategy. IN SPMS/ COMMITMENTS NO/NO QUANTITATIVE MEASURES (a) Identify, by Region, number and percent of stream miles, lake acres, estuary square miles, coastal miles, and Great Lake shore miles which are not meeting designated uses due .to NPS pollution. (b) Identify, by Region, Yes/No by non-point source category, WQ-22 the number and percent of stream miles, coastal miles, lake acres, estuary square miles, and Great Lakes shore miles not fully supporting designated uses due to NPS. (c) Track, by Region, Yes/SPMS against targets the number WQ-23 of adequate State NPS manage- ment programs developed or up- dated consistent with WQM Regulations and EPA's Non- point Source Strategy. (d) Identify, by State, the No/No number of these areas needing increased assistance from other Federal agencies to support project implementation. REPORTING FREQUENCY First Quarter Third Quarter Second/ Fourth Quarters Fourth Quarter SOURCE OF DATA 106, 205(j) Work Programs; 305(b) Reports ASIWPCA Assessments 106, 205(j) Work Programs; 305(b). 305(b). 106, 205(j) Work Programs, 106, 205(j) Work Programs, 305(b). ------- APPENDIX B ------- MUNICIPAL POLLUTION CONTROL QUANTITATIVE MEASURE DEFINmON/PERFORMftNCE EXPECTATION 3(a) % of projects that completed 3(a) Percent equals the number of projects that have an actual Affirmative the one year operational Project Performance Certification (actual KA date without corrective period and were affirmatively action) occurring during the period of time being rated divided by the certified. number of projects that completed the one year operational period (actual N7 date + 12 months) during the same rating period of time x 100. Performance Expectations: The target performance is that 100 percent of the projects will be affirmatively certified without corrective action, however, an accept- able performance could be 95 percent with the 5 percent non-affirma- tively certified projects having justifiable reasons. Justifiable reasons could include: what progress the Region and States have made towards ensuring that the project can be affirmatively certified, that the project is awaiting completion of corrective action as described in an acceptable Correction Action Report (CAR) or that implementation of the CAR* is pending review by enforcement and/or grants offices. The grantees submission of an acceptable CAR is expected 60 days after the end of the one year project performance period. Ha) Total dollar value (grant amounts) l(a) Preconstruction lag is defined as the grant amounts of all Step 3 projects in preconstruction lag status that have not initiated building within 9 months of grant award plus the expressed as a percent of annual grant amount of all Step 2+3 projects that have not initiated building allotment. within 9 months of approval of plans and specifications. The initiation of building is defined as the date of issuance of a notice to proceed for all significant elements of the project, or, if a notice to proceed is not required, the date of execution of all significant contracts on the project. GICS select logic for start of last significant elements is: KO "A ", "F ", "B ". Dollar amount of lag in KC can be reduced by use of data elements V7 and V8. Performance Expectation; Regions are expected to establish and submit to Headquarters a level (percentage) of preconstruction lags based on individual FY 1986 (actual) State allotments within the Region. Headquarters will review the proposed performance and analyze quarterly the Regional actions taken to achieve the expected level of performance. ------- MUNICIPAL POLLUTION CONTROL QUANTITATIVE MEASURE DEFINITION/PERFORMANCE EXPECTATION l(b) I of projects initiating operation. l(c) The measure is those projects (Step 3, Step 2+3 and PL 84-660) that actually initiated operation (actual N7 "Initiation of Operation" date for projects funded after 12/29/81 or actual N5 "Project Completion" for projects funded prior to 12/29/81) during the period of time being rated, compared to those targeted to initiate operations during the same rating period. Performance Expectation; The goal is that 100% of all those projects that are targeted in GICS to initiate operation during the rating period actually initiate operations. An acceptable performance is that at least 95% of the targeted projects actually initiate operations. r ------- MUNICIPAL POLLUTION CONTROL QUANTITATIVE MEASURE DEFINITION/PERFORMANCE EXPECTATION l(c) f of Step 3, Step 2+3 and PL 84-660 administrative completions. l(d) An administrative completion is any one of the following: 0 A final audit request: N8 = 'Ajrf1 or 'F#' or 'B#' or; 0 A project that is administratively complete but not sent to OIG because of related segments or phases: N8 = 'AP1, or; 0 A project not requiring a final audit: N8 = 'NS1. Final audit is requested when the following conditions have been satisfied: 0 Construction is complete as defined in data element N5, Project Com- pletion Code & Date; 0 All pre-final audit administrative requirements have been satisfied; 0 Final inspection has been performed; 0 The plan of operation has been implemented, or for projects awarded after December 29, 1981, an affirmative project performance certifi- cation has been received; or an acceptable corrective action report has been submitted. 0 The "cut-off" letter has been issued to the grantee; and 0 The final payment has been requested. Performance Expectations; All projects for which grants were awarded before December 29, 1981, are expected to be administratively completed within 12 months of physical completion. All projects awarded after December 29, 1981, are expected to be administratively completed within 18 months of initiation of operations. As a minimum target, the estimated number of projects awaiting administrative completion at the beginning of the fiscal year should be planned for administrative completion by the end of the fiscal year. Projects awarded after December 29, 1981, will not be considered as awaiting administrative completion until the 12 month project performance period has expired. Note; The two October 15, 1984 memos fron Jack Ravan and John Martin describe procedures for projects to be forwarded for final audit (administratively completed) when grantees haven't submitted final payments or where there are unresolved claims. ------- MUNICIPAL POLLUTION CONTROL QUANTITATIVE MEASURE DEFINITION/PERFORMANCE EXPECTATION l(d) * of Step 3, Step 2+3 and P.L. 84-660 closeouts. T l(e) Closeout occurs after: 0 Audit has been resolved or a determination has been made by OIG that an audit will not be performed 0 Funds owed the Government by the grantee (or vice versa) have been recovered (or paid); and 0 A closeout letter has been issued to the grantee; or 0 Any disputes filed under 40 CFR Part 30 have been resolved. Performance Expectations; Project closeout is expected to occur within 6 months after final audit resolution. However, the time-based measure will not apply if: 0 The grantee appeals a final decision in accordance with 40 CFR Part 30; or 0 The action official has referred the project to the servicing finance office to establish an accounts receivable based on the audit findings. 0 The grantee has failed to implement any grant condition or the project cannot be affirmatively certified because the required corrective actions have not been done. 0 Final audit has not been completed pending resolution of unresovled claims. As a minimum target, the estimated number of projects awaiting closeout or awaiting audit resolution at the beginning of the fiscal year or any project planned for 'screen out1 by OIG during the fiscal year should be planned for closeout by the end of the fiscal year. GICS select logic for closeouts is: P0 = 'Atf1 or 'AC1. ------- MUNICIPAL POLLUTION CONTROL QUANTITATIVE MEASURE DEFINmON/PERFORMftNCE EXPECTATION l(e) f of administrative completion l(e) An administrative completion backlog is any project that has been awaiting backlogs eliminated. administrative conpletion for more than 12 months at the beginning of the fiscal year, if it was awarded before December 29, 1981; or awaiting administrative completion for more than 18 months at the beginning of the fiscal year, if it was awarded after December 29, 1981. The status, or reason for delay, of every administrative completion backlog project should be reported to Headquarters on a quarterly basis via GIGS. Performance Expectation The goal is to complete all backlog projects during FY86. An in-depth review/analysis of each backlog project not scheduled for completion during FY 86 will be performed prior to the beginning of the fiscal year. If the Region/State believes that a particular backlogged project.cannot be administratively completed during FY 86, a short narrative (not GICS codes) should be submitted with the data request describing: ^ - past problems - current status - prognosis for administrative completion - the estimated administrative completion date Since the emphasis should be on completing older backlogged projects, only extraordinary reasons will be accepted for not administratively completing projects during FY 86 that are older than 36 months at the beginning of FY 86. An indepth review/analysis of projects not administratively completed by the end of the 2nd quarter FY 1986 and not expected to be administratively com- pleted during FY 1986 will also be performed during the mid-year evaluation. The October 15, 1984 OW/IG policy memos eliminated most reasons for delays. However, when supported by the project specific justification referenced above, a limited number of backlogged administrative conpletion actions may not be within the control of the State/Region. These could involve project- wide claims/litigation, ongoing Federal/State investigations or other activities which preclude the determination of administrative completion and the initiation of a final audit. ------- MUNICIPAL POLLUTION CONTROL QUANTITATIVE MEASURE DEFINITION/PERFORMANCE EXPECTATION l(f) t of closeout backlogs eliminated. T l(f) A closeout backlog is any project that has been awaiting closeout for more thah 6 months at the beginning of the fiscal year. The status, or reason for delay, of every closeout backlog project, should be reported to Headquarters on a quarterly basis via GICS. Performance Expectation; The goal is to complete all backlog projects except those projects delayed beyond the Region's or State's ability to control, i.e., 100% achievable closeout backlogs eliminated. An in-depth review/analysis of each backlog project not scheduled for closeout during FY 86 will be performed prior to the beginning of the fiscal year. The following are examples of sane of the delays that may occur during the closeout phase that are beyond the control of the Region or State: - Action awaiting debt collection by Financial Management; - Dispute pending under 40 CFR Part 30; - Corrective action (necessary for affirmative certification) not complete; and - Litigation If the Region/State believes that a particular backlogged project cannot be closed out during FY 1986, a short narrative (not GICS codes) should be submitted describing: - past problems - current status - prognosis for closeout - the estimated closeout date. An indepth review/analysis of projects not closed out by the end of the 2nd quarter FY 1986 and not expected to be closed out during FY 1986 will also be performed during the mid-year evaluation. ------- MUNICIPAL POLLUTION CONTROL QUANTITATIVE MEASURES Kg) % reduction of unliquidated obligations in a negotiated group of "slow moving" projects (SMPs). DEFINITION/PERFOMANCE EXPECTATION w Kg) A "slow moving" project (SMP) is defined as a Step 3, Step 2+3 or PL 84-660 project under construction that has paid-out less than 90% of funds awarded and either: 1) has not had a grant payment in over 6 months; or 2) has an outlay history that varies significantly from the 6/75 obligation payout curve. Projects under construction are those for which construction has been initiated as defined in l(a) above. Percentage of funds paid-out is defined as GICS data elements (63/19)X(100%). Grant increases during FY 1986 will not be added to the baseline against which performance is measured. Deobligations, however, will be included as reductions in unliquidated obligations since deobligating unnecessary grant funds is one strategy for reducing balances. The negotiated group of SMPs will include up to 20 projects and to the extent possible, will include the SMPs with the largest unliquidated obligations. The list should not include projects with impossible-to- resolve delays. Performance Expectation; Unliquidated obligations in the negotiated subset of projects will be reduced quarterly by a negotiated percentage. Specific quarterly commitment and the cumulative year-end commitment will be determined for each Region based upon data analysis and negotiations. ------- MUNICIPAL POLLUTION CONTROL QUANTITATIVE MEASURE DEFINITION/PERFORMANCE EXPECTATION l(h) t Of CMES. l(h) The objective of CMEs and FMCs is outlined in the Construction Management Evaluation and Project Management Conference Manual. Performance Expectation; The national target for CMEs during FY 1986 is 165, with the objective of two to five per State as shown in the following table based on the state-size established in the construction grants resource model: T 00 State Size Small Medium Large Super No. of CME's 2 3 4 5 Regions will lead or co-lead a significant number of CMEs. report will be submitted to Headquarters on each CME. A Regional Since a PMC is needed on virtually all new construction projects, the target is the number of construction starts expected during FY 1986. ------- MUNICIPAL POLLUTION CONTROL QUANTITATIVE MEASURE l(i) t of active Step 1's and Step 2's administratively completed or terminated during the year. DEFINITION/PERFORMANCE EXPECTATION l(i) A Step 1 or Step 2 project is considered administratively complete when a final audit is requested, or for projects that cannot be sent to OIG because of ongoing Step 2, Step 2+3, or Step 3 projects, when all of the admini- strative completion requirements have been satisfied. A Step 1 or Step 2 project is administratively complete when the following conditions have been satisfied: 0 The scope of work is complete as defined in data element N5, Project Completion Code and Date. 0 All pre-final audit administrative requirements have been satisfied. 0 The "cut-off" letter has been sent to the grantee. 0 The final payment request has been processed* 0 A grant amendment reflecting the final payment request has been issued, if one is needed. GIGS select logic for Step 1 and Step 2 administrative completion is one of the following: w vo A final audit request: N8 = or or 'B0' 0 A project for which all of the administrative completion requirements have been satisfied but has not been sent to OIG because of related Step 2, Step 2+3, or Step 3 project: N8 = 'AP1 0 A project with claimed cost less than $250,000 which does not require a final audit: N8 = 'NS1 Performance Expectation: The goal of the construction grants program is to administratively complete all Step 1 and Step 2 projects by the end of FY 1986 except large, compli- cated or involved projects. The Region will be expected to establish target dates and to report the status, or reason for delay, either manually or via GICS, for any Step 1 or Step 2 project scheduled for physical completion after FY 1985 or admini- strative completion after FY 1986. This information should be complete and maintained as of December 1, 1985. Note; The two October 15, 1984 memos from Jack Ravan and John Martin describe procedures for projects to be forwarded for final audit (administratively completed) when grantees haven't submitted final payments or where there are unresolved claims. ------- MUNICIPAL POLLUTION CONTROL QUANTITATIVE MEASURE DEFINITION/PERFORMANCE EXPECTATION 3(a) % of Corps utilization vs. target 3(b) * of final construction inspections conducted by the COE. 3(a) Although measure appears as a quantitative indicator, Headquarters does not regard it as a Regional commitment. The commitment is between Corps Divisions and EPA Regions. However, Headquarters does intend to track performance against plan in evaluating how effectively the Region is overseeing the Corps performance in the Region. 3(b) This is the inspection to determine that construction of a project is complete and it is determined that: 0 All construction associated with the last contract under that grant is complete in accordance with the approved plans, specifications and change orders; except for minor components (e.g., if all but landscaping is done). 0 All equipment is operational. 0 Laboratory facilities, if part of approved plans and specifications, are available to conduct tests as required. This is not the grant final inspection because the grantee will still be entitled to additional costs during the one year certification period. The Corps inspector may not be responsible for judging the potential efficiency or effectiveness of the wastewater treatment processes. Performance Expectation; A final construction inspection will be conducted on all grant projects approximately at the time of initiation of operation or physical completion. Accordingly, the commitment will be reviewed against the related SFMS commitment. ------- MUNICIPAL POLLUTION CONTROL QUANTITATIVE MEASURE DEFINITION/PERFORMANCE EXPECTATION 3(c) f of Project Management Conferences (PMC's) conducted by the COE. l(a) f of new activities delegated to the States. 2(a) % of cum. net monthly outlays (plan vs. actual) 2(b) % of cum. gross quarterly obligations (plan vs. actual). 3(c) The objective of a Project Management Conference (PMC) is outlined in the Construction Management Evaluation and Project Management Conference manual. PMC's provide detailed requirements of construction grant project manage- ment, guidance to grantees on record-keeping requirements, construction management techniques and overall grant project management procedures. Performance Expectation; A EMC should be conducted with virtually all new Step 3 and Step 2+3 grantees before the start of construction. Construction start is expected to take place within 9 months of Step 3 grant award or approval of the Step 2 portion of a Step 2+3. l(a) This measure is based on the number of new activities delegated to the State during the fiscal year. Source is the delegation matrix generated from the resource model available to the Region on request. The Region is expected to adhere to its approved delegation plan. If slippage in delegation occurs, it should be anticipated and accommodated in Region's resource usage. 2(a) The net sum of payments made and payments recovered from PL 84-660 projects, PL 92-500 section 206(a) reimbursable projects, PL 92-500 contract authority projects, as well as projects funded with Talmadge/Nunn, FY 1977 supple- mental, FY 1978 through FY 1986 budget authority, section 205(j) funds, and section 205(g) delegation funds. Region is expected to achieve a performance within +5% of its ocmmitment on a monthly basis. 2(b) Dollar amount of new awards and increases from projects funded with PL 92-500 contract authority, 1977 supplemental, FY 1978 through 1986 budget authority, section 205(j) funds and section 205(g) delegation funds. The amount does not include PL 84-660 and PL 92-500 section 206(a) reimbursable funds. Region is expected to achieve a performance within +15% of its commitment on a quarterly basis. Note: In accordance with Agency accounting practices, decreases of funds awarded in FY 1986 during FY 1986 will be subtracted frcm the gross total. ------- MUNICIPAL POLLUTION CONTROL QUANTITATIVE MEASURE l(a) I of Operations Management Evaluations (OMEs) performed at completed minor POTW's. DEFINITION/PERFORMANCE EXPECTATION ro l(a) An Operations Management Evaluation (ONE) is a problem diagnostic and onsite assistance program focused on small (generally under 1 mgd) POIWs. Candidate projects are identified through EMR or onsite reviews as having performance problems that are affecting or are likely to affect permit compliance by that plant. An OME includes a diagnostic evaluation to identify O&M management and facility performance problems, appropriate onsite assistance to help resolve identified O&M problems, and a report identifying compliance results and appropriate followup actions by EPA, State, and/or the community, needed to assure that the grantee/cotmunity meets continuing O&M management and permit compliance responsibilities. An OME is equivalent to work being performed currently by State Section 104(g)(l) grantees and will generally be performed by these grantees. Performance ExjpjBctation States and Regions are expected to commit jointly to assist not less than 10 percent of the minor mechanical POTWs in each State, but not to exceed 15 plants in any State. State commitments are expected to be based primarily on and contingent upon their Section 104(g)(l) grant cotmitments. Regional Offices are expected to commit to a negotiated level of OME activity in each State consistent with the FY 1986 resource allocation. If, as a result of Regional and State 104(g)(l) grantee efforts, minor facility performance and compliance are at such a high level that OME commitments cannot be achieved, Regions should provide an explanation at the end of the year. ------- PERMITS QUANTITATIVE MEASURES LmrjjTITION/PERPOBMANCE EXPECTATION Ka) I of permits reissued to major industrial facilities during fis- cal year (NPDGS States, non-NPDES States). to Kc) # of permits reissued to major municipal facilities during fiscal year (NPDES States, non-NPDES l(a) Total number of major (using MRAT system) industrial permits with issuance dates (i.e., date signed by permit authority) during BY 86. Status as of the close of the quarter will be taken from PCS on the 10th of the month following the end of a quarter. Of the major permits issued, the number that are priority permits will be determined from the priority permits list developed by the Regions. This will be compared to the total number of major (using MRAT system) industry permits with expiration dates before October 1, 1986 according to PCS data on October 10, 1985 (i.e., the number of major industrial permits that have or will expire by the end of FY 86). Performance Expection; The goal of the State and EPA NPDES Permits Programs is to eliminate the backlog of expired permits for major facilities and have reissued major permits in effect on the date the prior permit expires. Permit applications are due and should be acted upon during the last six months of a permit's term. Most States and Regions, once they have eliminate the backlogs that have accumulated over the past few years, should be able to reissue 100% of their expiring major permits except where unusual, complex and difficult issues prevent timely permit reissuance. Backlogs consistently over ten percent of all permits (major and minor) are unacceptable. l(c) Total number of major municipal permits with issuance dates (i.e.,date signed by permit authority) during FY 86. Status as of the close of the quarter will be taken from PCS on the 10th of the month following the end of a quarter. This will be compared to the total number of major municipal permits with expiration dates before October 1, 1986, according to PCS data on October 10, 1985 (i.e., the number of major municipal permits that have or will expire by the end of FY 86). Performance Expectation; The goal of the State and EPA NPDES Permits Programs is to eliminate the backlog of expired permits for major facilities and have reissued major permits in effect on the date the prior permit expires. Permit applications are due and should be acted upon during the last six months of a permit's term. Most States and Regions, once they have eliminate the backlogs that have accumulated over the past few years, should be able to reissue 100% of their expiring major permits except where unusual, complex and difficult issues prevent timely permit reissuance. Backlogs consistently over ten percent of all permits (major and minor) are unacceptable. ------- PEWtLTS QUANTITATIVE MEASURES DEFIMTION/PERFORMftNCE EXPECTATION Ke) Kf) Region's lists of major industrial and municipal permits to be issued in non-NPDES States in FY 86. NPDES State's list of major industrial and municipal permits to be issued in FY 86. l(e) The lists of major industrial and municipal permits to be issued in non-NPDES States in FY 1986 is to be developed under provisions of the "Policy for the Second Round Issu- ance of NPDES Permits for Industrial Sources'1 and the "National Municipal Policy," respectively. Permits on these lists are known as priority permits. If there are no priority permits in a State, this should be noted. l(f) The lists of major industrial and municipal permits to be issued in NPDES States in FY 1986 which are developed by each NPDES State in the same way as EPA's major permit issuance lists (see item l(e) above). These lists are to be provided to the respective EPA Regional Office at the beginning of FY 1986. ------- PERMITS QLlftNTITATIVE MEASURES DEFINmON/PERFORMANCE EXPECTATION Kg)/(h) "f of major industrial/municipal permits modified/reopened (NPDES States; non-NPDES States)" t-t en f of permits reissued to signifi- cant minor industrial/municipal facilities during fiscal year (NPDES States, non-NPDES States). l(g)/(h) Permit Reopener; A predictable change to a permit which result from a specific reopener clause in the permit, triggered by specific events such as the promulgation of an effluent guide- line, the promulgation of a section 307(a) toxic effluent standard or prohibition, results of a biomonitoring program, necessary modifications to local pretreatment programs, or a variance. Permit Modifications; A less predictable change to a permit which does not result from a specific reopener clause in the permit. Examples include changes resulting from a request from the permittee, new information, negotiated settlements, judicial decisions, or other events listed in 40 CFR 122.62(a) which are not "reopeners" as defined above. l(i)/(j) Total number of significant minor industrial/municipal permits with issuance dates (i.e., date signed by permit authority) during FY 86. The Region is to report separately for POIWs and industry (industrial number may include other non-municipal dischargers) in each NPDES State and non-NPDES State. Because this is the first year the issuance of "significant minors" will be tracked, their definition is in the form of guidance on the characteristics of a significant minor. The planned development of a national strategy for the issuance of minor permits is expected to lead to a more refined definition. Significant minor dischargers should be distinguished by their clearly definable environmental impact when compared to other minor dischargers. Minor dischargers may be more important (significant) because they impact a priority waterbody or have a high potential for degrading water quality during periods of high production or low flow. On the other hand, minor dis- chargers may be considered not "significant" when controls external to the NPDES program mitigate the wastewater dis- chargers or their impact on receiving waters. The nexus be- ------- PERMITS QUMTTITATIVE MEASURES DEKLNITION/PERFORMMKE EXPECTATION l(k) Prepare strategy for each State for the issuance of permits to minor dischargers. tvieen point and non-point source controls should also be considered when determining the significance of a minor dis- charger. The basic test is: which minor dischargers, if issued current permits* would produce the greatest environmen tal benefit. Their number would be limited by reason and resources. A strategy for minor permit issuance is to be prepared for each State by the permitting authority based on the national minor permit issuance strategy currently scheduled for release on October 31, 1985. The strategy should consist of two specific elements. First, it should list individual priority ranking factors (such as the presence of toxics, water quality considerations and geographical distributions) Which will be used to divide each State's universe of minor permits into priority groups. The strategies should distinguish industrial and municipal permits since there may be some differences in priority associated with these dischargers. Second, the strategy should contain details of implementation including methods used for issuance such as general permits, model permits, etc., and the resources assigned to this activity. These strategies are to be used in preparing list of significant minor permits which will be required as a part of the FY 87 commitment process. ------- PERMITS QQWrrrflTIVE MEASURES 2(a)/(b) # of evidentiary hearing requests pending at beginning of FY; and the number of those resolved in EY 1986 (NPDES States, ncn-NPDES States): -Municipal; and -Non-nunicipal. 2(c)/(d) f of evidentiary hearings requested during FY 86 and the f of those FY 86 requests' which are denied or granted within 90 days (NPDES States, non- NPDES States): - Municipal; and - Non-nunicdpal. 3(a)/(b) f of direct discharger variance requests pending at beginning of EY 86; f denied and # forwarded to Headquarters with a recommendation in FY 86 (NPDES States, ncn-NPDES States): -FDF -301 (c) -301(g) -301 (k) -316(a) -316(b) 2(a)/(b) The Region is to identify by 10/31/85 the nunber of eviden- tiary hearing requests that are pending at the beginning of FY 86. Oonmitraents are to be made to eliminate that carryover by resolving all those pending requests during FY 86. Resolution consists of either denial, settlement, or formal hearing initiated. The Region is to report quarterly the cumulative number of each of the following occurring in FY 86: (1) denials; (2) settlements; and (3)fomal hearings initiated. Municipal and non-municipal are reported separately for each NPDES State and ncn-NPDES State. 2(c)/(d) The Region is to report each quarter, State-by-State, the cumulative number of new evidentiary hearing requests received in FY 86 and, of those, the cumulative nunber which are denied cur granted within 90 days. This measures initial action to mitigate future carryover. Except for those denied, it does not measure resolution of eviden- tiary hearing requests. 3(a)/(b) The Region is to identify by 10/31/85 the number of vari- iance (and deadline extension) requests from direct dischargers by type (PDF, 301(c), etc.) that are pending at the beginning of FY 86. Commitments are to be made to eliminate that carryover by acting on all those pending requests during FY 86. Such action consists of either denial or referral to Headquarters with a Regional recom- mendation. The Region is to report quarterly the emulative nunber of denials during FY 86 and the cumulative nunber of recommendations forwarded to Headquarters during FY 86, by type of variance in each NPDES State and ncn-NPDES State. ------- PERMITS QUANTITATIVE MEASURES 3(c)/(d) * of direct discharger variances requested during BY 86 and the # of those acted upon (NPDES States, non-NPEES States): DEFINITION/PERFORMANCE EXPECTATION 3(c)/(d) The Region is to report each quarter, State-by-State, the nurttoer of each type of new variance request received from direct dischargers in FY 86 and, of those, the nunber acted upon. The quarterly report of those new variance requests acted upon is to provide the cunulative nunber of denials and the cunulative nunber of reccmnendations forwarded to Headquarters during FY 86 by type of variance in each NPCES State and non-NPDES State. w H* 00 ------- ENFORCEMENT QUANlTliftTIVE MEASURE ua?'lMn-ICN/PERPDBMRNCE EXPECTATION l(a)-(b) MOVING BASE (-• so 1. M3VING BASE measures compliance levels of all major permittees each quarter, and of minor P.L.92-500 permittees send-annually. A facility is considered to be on final effluent limits When the permittee has completed all necessary construction (including all start-up or shakedown period specified in the permit or enforcement action) to achieve the ultimate effluent limitation in the permit reflecting secondary treatment, BPT, BAT, or more stringent limitations, such as State required limitations or water quality based limitations, or limitations established by a variance or a waiver. A facility on a "short-term" schedule (one year or less) for corrections such as composite correction plans, where compliance can be achieved through improved operation and maintenance (rather than construction) is considered to be on final effluent limits. A facility is considered to be in significant nonconpliance with final effluent limits when it has exceeded the criteria for significant nonconpliance with its final effluent limits, compliance schedule or reporting requirements and has not been resolved by the end of the reporting period. Further discussion of significant nonconpliance and its resolution can be found in the Gudiance for Preparation of Quarterly and Sena- Annual Nonconpliance Reports (per section 123.45, code of Federal Regulations, Title 40). A facility is considered to be "not on final effluent limits" if the permittee does not meet the definition of a "facility on final effluent limits" or when a permit, court order/consent order or an Administrative Order require construction such as for a new plant, an addition to an existing plant or a tie-in to another facility. A facility is considered to be in significant nonconpliance with its construction schedule when it has exceeded the criteria for significant nonconpliance with its construction schedule or schedule reporting requirements and has not been resolved by the end of the reporting period. A facility is considered to be in significant nonconpliance with its interim effluent limits when it has exceeded the criteria for ------- QUANTITATIVE MEASURE l(a)-(b) MOVING BASE (Cont'd) ENFORCEMENT DEFINITION/PERFORMANCE EXPECTATION significant nonconpliance with its interim effluent limits or measurement reporting requirements and has not been resolved by the end of the reporting period. A facility which is in significant nonconpliance with both its construction schedule and interim limits should be considered as in significant nonconpliance with its schedule only. Major P.L.92-500 permittees are tracked as part of the major municipals as well as being tracked separately. w ro o ------- ENFORCEMENT QUAOTITftTIVE MEASURE EXPECTATION 2(a)-(b) NATIONAL MUNICIPAL POLICY 3(a) ACKENISTRATIVE ACTIONS 3(b) CLOSE-OUTS 2. Compliance schedules are expected to be established on the priority basis established in the National Municipal Policy. The goal was to establish enforceable schedules for all affected municipalities (municipalities which require capital improvements in order to meet the statutory requirements) by the end of FY 1985. 3. Headquarters will report EPA Administrative Orders (AOs); Regions will report State equivalent actions. EPA AOs must arrive at Headquarters by the fourth working day of the new quarter in order to be counted in the report. (Includes pretreatment AOs) 3. An AO will be considered closed-out when the requirements of the order have been completed in full or a judicial action has been referred to HQ or DOJ. T to 3(c) 3. Federal referrals will be reported by the Office of Enforcement and Compliance Monitoring (OECM); State referrals will be reported by the Regions. (Includes pretreatment referrals) 3(d) CONSENT DECREES 3(e) EMR/Cft 3. Remedial actions include decree modifications, contempt actions, collection of stipulated penalties, and other activities as defined in the OECM guidance. 3. EMR/OA. followup includes the following: Nonrespondents - nonrespondent notices; when necessary, afljI'MrifvO phone calls and letters; Permittees requiring corrective action - ascertain from permittee sources of errors and corrective actions to be taken; Both - use for planning compliance inspections. ------- ENFORCEMENT (oont.) QUANTITATIVE MEASURES DEFINrnON/PERFDRMANCE EXPECTATION 2(a)-(b) EXCEPTION LIST w ro In regard to all major permittees listed in significant non- compliance on the Quarterly Nonoompliance Report (QNCR) for any quarter, Reglons/NPDES States are expected to ensure that these facilities have returned to compliance or have been addressed with a formal enforcement action by the permit authority within the following quarter (generally within 60 days of the end of that quarter). In Hie rare circumstances where formal enforcement action is not taken, the administering Agency is expected to have a written record that clearly justifies why the alternative action (i.e., informal enforcement action or permit modification) was more appropriate. Where it is apparent that the State will not take appropriate formal enforcement action before the end of the following quarter, the States should expect the Regions to do so. This translates for exception list reporting as follows: EXCEPTION LIST reporting involves tracking the compliance status of major permittees listed in significant noncompliance on two or more consecutive QNCRs without being addressed with a formal enforcement action. Reporting begins on January 1, 1986 based on permittees in SNC for the quarters ending June 30, and September 30, that have not been addressed with a formal enforcement action by December 1. Regions are also expected to complete and submit with their exception list a fact sheet which provides adequate justification for a facility on the exception list. Reporting is to be based on the quarter reported in the QNCR (one quarter lag). Returned to compliance for Exception List facilities refers to compliance with the permit, order, or decree requirement for which the permittee was placed on the Exception List (i.e. same outfall, same parameter). Compliance with the conditions of a formal enforcement action taken in response to an Exception List violation counts as an enforcement action (rather than return to compliance) unless the require- ments of the action are completely fulfilled and the permittee achieves absolute compliance with permit limitations. ------- ENFORCBIEdT (cent.) QUWJLMTAT1VE MEASURES 2(a)-(b) EXCEPTION LIST foont'd) Formal €n£c tt actions against non-federal permittees include any statutory remedy such as Federal Administrative Order or State equivalent action, a judicial referreal (sent to HQ/DOJ/SAG), or a court approved consent decree. Formal enforcement actions against federal permittees include placing them on an acceptable construction shedule or compliance agreement, documenting the dispute and forwarding it to Headquarters for resolution, or granting them Presidential exemption. T 10 ------- QUANTITATIVE MEASURES ENFORCEMENT (oont.) EEFINITION/PERFOBMMICE EXPECTATION l(a)-(b) PCS T to *- 2(a)-(c) INSPECTIONS 1. WENT® elements are the core of information necessary so that PCS can function as a useful operational and management tool and can be used to conduct oversight of the effectiveness, or overall health of the NPDES Program. The list of WENDB elements can be found in the PCS Policy Statement. It includes permit facility, permit event, parameter limits, pipe schedule, inspection, evidentiary hearing, compliance schedule, measurement, and enforcement action data. Regions are expected to attain 100% data entry of WENDB elements for majors, minor 92-SOOs, and other minors as required by the PCS Policy Statement. The $ indicator for P.L. 92-500 permittees is to be entered as soon as a permittee who constructed using P.L. 92-500 funding is completed and operational, and the final inspection is approved. The F indicator for permittees on final effluent limits is to be entered as soon as the permittee fulfills the definition of a permittee on final effluent limits. 2. Regional and State inspection plans should be established by BY 1986 in accordance with guidance on inspection plans. As the inspection strategy states, all major facilities should receive the appropriate type inspection each year by either EPA or the State. EPA and States collectively cotmit to the number of major permittees inspected each year with a Compliance Evaluation Inspection (CEI), Compliance Sampling Inspection (CSI), Toxics Inspection (TOX), Biomonitoring Inspection (BIO), Performance Audit Inspection (PAI), Diagnostic Inspection (DIAG), or Reconnaissance Inspection (RI). Reconnaissance Inspections will only count toward the ------- QUAOTITM'IVE MEASURES 2(a)-(c) INSPECTIONS (Gont'd) ENFORCEMENT (Oont'd) DEFIM1T10N/PERPOPMRNCE EXFBL.'iATICN oGnmitnent when they are done on facilities that meet the following criteria t (1) Hie facility has not been in SMC for any of the four quarters prior to the Inspection. (2) The facility is not a primary industry as defined by 40 CFR, Part 122, Appendix A. (3) The facility is not a municipal facility with a pretreatment program. 10 in Commitments for major permittee inspections should be quarterly targets and are to reflect the number of major permittees inspected at least once. The universe of major permittees to be inspected is defined as those listed as majors in PCS as of July 31, 1985. Multiple inspections of one major permittee will count as only one major permittee inspected (however, all multiple inspections will be included in the count for the measure that tracks the total number of all inspections - see next paragraph). When conducting inspections of POTWs with approved pretreatment programs, a pretreatment inspection component should be added. An NPDES inspection with a pretreatment component will be counted toward the commitments for majors, as well as toward the commitment for pretreatment inspections. (This will be automatically calculated by PCS.) Regions are encouraged to continue CSI inspections of POTWs where appropriate. The measure for tracking total inspection activity will not have a commitment. CEI, CSI, TOX, BIO, PAI, and DIAG of major permittees, minor P.L. 92-500 and significant minor permittees will be counted. Pretreatment inspections will not be counted in the total. Multiple inspections of one permittee will be counted as separate inspections; Reconnais- sance Inspections will be counted. It is expected that up to 10% of EPA resources will be set aside for neutral inspections or minor facilities. ------- QUANTITATIVE MEASURES ENFORCEMENT (oont) CEFTNITION/PERFORMRNCE EXPECTATION 2(a)-(d) INSPECTIONS (oont'd) Tracking of Inspections will be dene at Headquarters based on retrievals from the Permit Compliance System (PCS) according to the following schedule: INSPECTIONS July 1, 1985 through Sep. 30, 1985 July 1, 1985 through Dec. 31, 1985 July 1, 1985 through March 31, 1986 July 1, 1985 through June 30, 1986 RETRIEVAL DftTE Jan. 8, 1986 April 4, 1986 July 9, 1986 Oct. 8, 1986 w to Inspections may not be entered into PCS until the inspection report with all necessary lab results has been completed and the inspector's reviewer or supervisor has signed the completed 3560-3 form. ------- PRETREA3MENT QUMflTJLftTIVE MEASURES l(b) t of local pretreatroent programs approved during EY 1986 (list separately: ncn-pretreatroent States, approved pretreatment States). DEFINITION/PERFORMANCE EXPECTATION to l(a)/(b) f of local pretreatnent programs audited/inspected during FY 1986 (for audits I list separately; non- pretreatment States, approved pretreatment States; for inspections list separately; States, EPA). l(b) A local pretreatment program is considered approved When, after appropriate public notice and comment, the Approval Authority (Regional Administrator or the State Director) approves the local program. Commitments for non-pretreat- ment States and for approved pretreatment States are to reflect all programs that are required but are not approved as of September 30, 1985. Referral actions will be con- sidered when assessing progress toward achieving commit- ments. Referrals that, in fact, have been turned over to the Justice Department will count as the equivalent of an approved program. l(a)/(b) A local pretreatment program audit is a detailed on-site review of an approved program to determine its adequacy. The audit report identifies needed modifications to the approved local program and/or the POflW's NPDES permit to address any problems. The audit includes a review of the substantive requirements of the program, including local limits, to ensure protection against pass through and interference with the treatment works and the methods of sludge disposal. The auditor reviews the procedures used by the POTW to ensure effective implementation and reviews the quality of local permits and determinations (such as implementation of the combined wastestream formula. In addition, the audit includes all the elements of a pretreat- ment compliance inspection(PCI). At a minimum, audits should be performed at all POTWs which have been approved for a year or longer and have not pre- viously been audited. Although an audit includes all the elements of a PCI, the activity should not be counted as both an audit and a PCI; it should be counted as an audit. In any given year, all POTWs that are not audited should have a PCI as part of the routine NPDES inspection at that facility. ------- PRETREATMENT QUANTITATIVE MEftSURES l(a)/(b) t of local pretreatment programs audited/inspected during EY 1986 (list separately: non-pretreatment States, approved pretreatinent States). (Gont'd) Ufclb'INITION/PERPQPMftNCE EXPECTATION l(a)-(c) PRETREATMENT Enfc nt ro oo The pretreatinent compliance inspection (PCI) assesses POTW ccnplianoe with its NPDES permit requirements for implementation of its approved pretreatinent program. A routine PCI should ensure that IU permits (or analogous documents where applicable) are actually issued. The PCI should review industrial user compliance rates (with both categorical standards and local limits) and POTW enforcement activities including its review of IU self-monitoring reports. (The PCI module is currently in draft. It may be necessary to revise this definition when the module is complete) Par purposes of reporting, both audits and pretreatinent compliance inspections should be lagged by one quarter (i.e., same as NPDES inspections). Pretreatinent Inspections will be tracked on three levels: Pretreatinent Inspections of approved POTWs (see definition of NPDES inspections), Pretreatinent Inspections of Industrial Users (IUs) in unapproved POTWs, and Pretreatment Inspections of IUs in approved POTWs. Priority for IU Pretreatinent Inspections is to be given to IUs in unapproved POTWs that are subject to Federal categorical standards. It is assumed that all Pretreatinent Inspections of IUs in approved POTWs are done subsequent to an inspection of the POTW, and that the POTW's records provide sufficient cause to question their regulation of the IU or the IU's performance, or that there is other cause to question the IU's performance (i.e., complaints, inquiries). Pretreatinent enforcement actions (AOs and referrals) will be incorporated into the total actions as well as being counted separately. An enforcement action for multiple violations must be counted only once; therefore, Headquarters will assume that the total actions minus pretreatinent actions will equal non-pretreatment NPDES actions. "State" enforcement actions (AOs and referrals) include actions by States with approved pretreatinent authority and actions by NPDES States for violation of a pretreatinent requirement of an NPDES permit. ------- STATE PROGRAMS QUANTITATIVE MEASURES l(a) Achieve NPDES program approvals and modifications in accordance with established schedules: - Full NPDES programs; - Pretreatment Program modifications; - Federal facility modifications u N5 VO l(a) Update list of NPDES States for which Region will assess statutory and regulatory authority in FY 86. DEFINITION/PERFORMANCE EXPECTATION Performance Expectation; Acceptable Regional performance is having and actively pursuing a current written strategy for each State to achieve full NPDES program adminis- tration which was prepared by the Region in consultation with the State/ identifies the obstacles to full program approval and sets forth a work plan for overcoming the obstacles. The work plan should describe what needs to be done, make recommendations on how it can be accomplished, and provide needed and reasonable estimates of time required. Performance Expectation The Region's goal should be to conduct a complete review of the statutory and regulatory authority for all NPDES State programs by the end of FY 1986. An acceptable performance will be the completion of these reviews for all States approved before 1980 and ccnpletion of a self-evaluation by all States approved since 1980. Where several NPDES State programs remain to be reviewed in FY 86, a minimum level of acceptable performance is to initiate three State reviews. ------- UNDERGROUND INJECTION CONTROL PROGRAM QUANTITATIVE MEASURE u> o 1 (b) Permit determinations made DEFINmON/PERPORMANCE EXPECTATION 1 (c) Class II well record files reviewed 1 (d) Mechanical Integrity Tests (MIT) performed „ 1 (e) MIT Witnessed 1 (f) Field Inspections conducted 1 (h) Major wells 1 (j) Formal enforcement action 2 (a) Permit determinations made Identify, by State, the total nunber of new and existing permit determinations (issued or denied) for (1) Class I wells and (2) Classes III, II and V (if apli- cable in FY 1986. Count permit determinations made only for those applications with the final document signed by the State Director in that reporting period. Count each area permit as one permit, and note the total number of wells that the area permits covered. Identify, by State, the I of Class II wells that the State has reviewed in ac- cordance with the 1425 program guidance. For multiple wells in a single field under an area permit or project, report the total I of wells that are covered in the same well record file. Identify, by State, the total I of wells with Mechanical Integrity Tests per- formed by the operators and verified by the State director. Identify, by State, the total I of wells with mechanical integrity tests per- formed by the operators and witnessed by the State field inspectors. Identify, by State, the I of injection wells inspected, including all routine, periodic, complaint investigation or follow-up inspections performed to determine compliance with permit or rule requirements or other program related activities. A Class I or Class IV wall An administrative order (AOs) or State equivalent or civil/criminal referral. Same as 1 (b). In making FY 1986 commitment. Regions should report the total estimated number of permits to be determined in FY 1986. This includes both existing and new permits and these numbers will be used as the base for FY 86 resource allocations in the C220 and C306 Workload Model. When reviewing permit applications, the priority is established as follows: 1. new Class II wells 2. existing Class I walls 3. existing Class III wells 4. new Class I and III wells ------- UNDERGROUND INJECTION CONTROL PROGRAM QUANTITATIVE MEASURE 2 (b) Permit elapsed time DEFINITION/PERFORMANCE EXPECTATION 5. existing Class II SWD wells. The permit elapsed time is the total f of calendar days fron the date a complete permit application is received and accepted by the Region to the date the final permit is signed by the program director (either permit issuance or permit denial). The average permit elapsed time is based on the average I of calendar days for all permit determinations made in a Region in a reporting quarter. ------- UNDERGROUND INJECTION CONTROL PROGRAM QUANTITATIVE MEASURE DEFINITION/PERFORMANCE EXPECTATION 2 (c) Class II well record files Same as 1 (c). reviewed 2 (d) Mechanical Integrity Test Same as 1 (d). performed 2 (e) MIT Witnessed Same as 1 (e). 2 (f) Field Inspection conducted Sane as 1 (f). 2 (g) Major well Same as 1 (g). 2 (i) Formal enforcement action Sane as 1 (i). ------- PUBLIC WATER SYSTEM SUPERVISION PROGRAM QUANTITATIVE MEASURE DEFINITION/PERFORMANCE EXPECTATION 7 to 2(a) How much money has been obligated? 5(a) Report the number of states with compliance strategies. 5(b) Report the numbers of civil cases referred, civil cases filed, and criminal cases filed against com- munity water systems which violated a microbiological, turbidity, or trihalomethane, MCL or monitoring/ reporting (M/R) requirement. 5(c) Report the number of states which have documented their approach to, or concept of, timely and appropri- ate enforcement. 5(d) Report, against targets, for primacy and non-primacy states, the I and % of community water systems with per- sistent MCL and M/R violations of the microbiological, turbidity and trihalomethane requirements. 5(e) Report, against targets, for primacy and non-primacy state, the # and % of community water systems in full compliance (i.e., with no MCL & M/R violations of the microbiological, turbidity and trihalomethane re- quirements during the 12 months of the reporting period). 2(a) This measure will report the amount of money from the PWSS Grant Direct Implementation funds'which has been obligated. 5(a) This measure will report the number of States which have developed compliance policies for dealing with systems which have violations of the NIPDWR. The National Compliance Policy was distributed January 18, 1984. 5(b) Definitions for these terms were provided previously. Regions should verify with the states that the data entered in the PROS enforcement file for these measures is accurate. 5(c) This measure will report the number of States which have documented their concept, or goal, of what constitutes timely and appropriate enforcement action. 5(d) This information is compiled by the Region from quarterly state compliance reports, which the Region then enters into the FRDS. ODW will extract the compliance information from the PROS. 5(e) This information is compiled by the Region from quarterly state compliance reports, which the Region then enters into the FRDS. ODW will extract the compliance information from the FRDS. ------- PUBLIC WATER SYSTEM SUPERVISION PROGRAM QUANTITATIVE MEASURE DEFINmON/PERFDRMANCE EXPECTATION 5(£) Report the population served by community systems with persistent MCL and M/R violations of the microbiological, turbidity, and trihalonethane requirements. 5(g) Report the number of states which have developed state inspection/ sanitary survey policies. 5(h) Report, separately, against targets, the numbers of CWBs which received; a) a routine prescheduled sanitary survey, or b) an inspection initiated because of a violation. (Report separately for each category) . 5(f) This measure will indicate the total population served by community water systems that persistently violate the micro- biological, turbidity, and trihalcmethane requirements. 5(g) This measure will indicate the number of states which have documented their policy on how they use inspections and sanitary surveys both as a preventative measure to protect public health and as an enforcement tool. 5(h) This measure will indicate how many ccnnunity water systems are routinely surveyed as a preventative tool and how many are inspected as a result of the system violating one of the states drinking water requirements. 5(i) Report the number of data verifi- cations completed. S(i) This measure will report the number of States in which data verification were conducted in FY 85. ------- WATER QUALITY STANDARDS, PLACING, AND ASSESSMENT QUANTITATIVE MEASURE Kb) Identify the nunber of stream miles/ lake acres, estuary square miles, coastal miles and Great Lakes shore miles in each Region, the number assessed, and numbers supporting/partially supporting/not supporting designated uses as reported in the FY 1986 305(b) report. DEFINITION/PERFORMANCE EXPECTATION l(c) Track, by Region, against targets, the number of States which incorporate new or revised numeric or narrative criteria for toxic pollutants into State Water Quality Standards that are approved by the Regional Office. 2(a) Identify, by Region, from the list of waters not fully supporting designated uses, the number of waterbodies needing water quality based controls and the number of TMDLs needed in these waters. This measure was developed as part of the STEP process. These data will be available from the State water quality assessment reports, which are to be submitted to EPA under CWA §305(b) by April 1, 1986. EPA guidance for pre- paring 305(b) reports describes how assessments are to be done. The Office of Water will carpile the data from State submissions or Regional EMRs. Although this aggregated measure asks only for "stream miles," it will be inportant in other measures to report the specific waterbodies, or numbers of waterbodies, such as waters needing TMDLs or waters not fully supporting uses. This information can form the basis for development of a priority waterbodies list, a tool to help States allocate resources to their most critical water quality problems, where abatement and control decisions are most needed to prevent or reverse impairment of a designated use. Targets will be negotiated with the Regions based on the number of States expected to ccnplete WQS review and submit revisions for approval in FY 86. Standards reviews will determine on a case-by-case basis which toxic pollutants and how many will be sufficient in each State. Reviews and approvals will be done in accordance with the Water Quality Standards Regulation, November 8, 1983. This item translates the "stream miles" reported above into a measure of "number of waterbodies," or areas where water quality based controls and TMDLs/WLAs are needed. ------- WATER QUALITY STANDARDS, PLANNING, AND ASSESSMENT QUANTITATIVE MEASURE 3(e) Track, by Region, against targets, the number of TMDLs completed in these waters. l(c) Track, by Region, against targets the number of States which develop an adequate NFS management program consistent with WUM Regulations and EPA's Non-point Source Strategy. DEFINITION/PERFORMANCE EXPECTATION This measure tracks progress against the targets for TMDLs/WLAs to be conducted during FY 86, established in negotiations. Reporting occurs in the last two quarters because most TMDLs are completed during the summer field season. This measure is designed to track the progress of States in developing and/or updating WQM plans to include fully adequate non-point source strategies. In evaluating the adequacy of these strategies, the Regions should use the model plan included in the Non-point Source Strategy, as well as the Water Quality Management Regulations. T ------- |