PERMIT PROGRAM
GUIDANCE FOR SELF-MONITORING
AND REPORTING REQUIREMENTS
OFFICE OF WATER ENFORCEMENT
-------
FOREWORD
On October 18, 1972, the Federal Water Pollution Control Act
Amendments of 1972 were enacted. One major feature of this sweeping
revision of the Federal water pollution laws was the establishment
of a new national permit system, which is defined in Section 402
of the Act as the National Pollutant Discharge Elimination System.
According to this section, permittees will be required to monitor
their discharges, to keep records of monitoring activities and to
report periodically on what is occurring with regard to these
discharges.
The purpose of this program guidance is to assist the EPA and
State regulatory agencies establish a sound, practical self-mom*toring
and reporting program. National guidance such as this must be
flexible in order to be applicable to the diversity of water pollution
problems throughout the country. It is hoped that this guidance will
encourage the development of more sophisticated monitoring programs,
which will improve the capability of municipal and industrial dischargers
to meet their permit limitations.
This program guidance is available upon request and will be given
broad distribution especially to those regulatory agencies involved in
monitoring activities. It may be revised periodically in order to
accomodate policy decisions and new developments. Further copies may
be ordered by writing to the Office of Water Enforcement, Permit
Programs Division, Room 706, Crystal Mall Building Number 2, Environmental
Protection Agency, Washington, D.C. 20460.
October 1, 1973
-------
TABLE OF CONTENTS
Introduction
Monitoring and Reporting
Industrial
Table I - Parameters to be
Reported
Table II - Minimum Sampling and
Analysis Frequency
for Process Effluent
Municipal
Table III - Municipal Wastewater
Treatment Facilities
Minimum
Sampling Frequency
Figure I - Monitoring Report Form
(3220-1)
Monitoring Forms
Reporting Schedule
Excessive Pollutant Discharges
Data Management - Introduction
System Description
Figure II - Flow Diagram for
Processing of Discharge
Monitoring Report
(Version A)
Figure III - Flow Diagram for
Processing of Discharge
Monitoring Report
(Version B)
Table IV - Uses and Costs of Time
Sharing Terminals
Section I
Section II
Page
1
2
2
6
7
8
9
10
11
11
12
12
13
14
17
-------
TABLE OF CONTENTS (Cont'd)
Page
Table V - States Presently having
Remote Computer Terminals 18
Figure IV - Monitoring Flow Chart 20
Table VI - Estimate of Automated
Data Processing Costs
of Self-Monitoring
Program 21
-------
Introduction
The following considerations are intended to delineate a practical
approach to the self-monitoring and reporting requirements of the
National Pollutant Discharge Elimination System under the Federal
Water Pollution Control Act Amendments of 1972. The material contained
in this document sets forth minimum requirements to insure national
uniformity as guidance to those administering the NPDES. The Permit
Program as a matter of policy should require such self-monitoring and
reporting by a permittee as is necessary to reasonably assess his
performance. Excessive data collection can be costly for the discharger
who must pay for the analytical effort, as well as for Regulatory
Agencies who must record and review the data. However, frequency of
sampling, analysis, and reporting must be such as to enable reasonable
assessment of the discharger's performance relative to his Discharge
Permit effluent limitations, and relative to his potential impact on
the environment. In order to determine appropriate requirements for
a given discharger, certain considerations must be taken into account,
including, but not limited to, State priority, effluent volume,
economics of data gathering (and processing), discharger's previous
history, potential public health hazards, receiving water use, and such
other considerations as may be appropriate. Monitoring manuals out-
lining specific methodology have been published by the Water Pollution
Control Federation, and by State Agencies. EPA is currently publishing
a monitoring manual which will soon be available for distribution.
The purpose of self-monitoring and reporting effluent data is to
permit Federal and State regulatory agencies to follow, on a continuing
basis, the discharger's effluent quality trends as well as specific
variations from established limitations. It also provides the discharger
with a minimum data review at least equal to that afforded the Regulatory
Agency to judge the efficiency of wastewater treatment operations and
the adequacy of pollution abatement programs. The principal use of self-
monitoring data by the regulatory agency will be to assess compliance
with Permit limitations. Self-reported data indicating permit violations
may be used as primary evidence in an enforcement action. In many cases,
however, efforts will be made to verify or supplement such data through
EPA or state surveillance investigations and monitoring activities.
Where independent evidence is thus gathered by the regulatory agency,
self-monitoring data will be used as corroborative evidence in an en-
forcement action.
As a general rule, data gathering other than that necessary to
assess compliance with specific limitations should not be required.
Monitoring and reporting requirements for municipal and industrial
dischargers will differ because industrial limitations are based on best
practicable control technology currently available whereas municipal
discharges are based on secondary treatment. Notwithstanding these
differences each permit should address itself to the definition of a
sample type, the frequency of analysis, the list of parameters to be
analyzed, and the frequency of reporting to the regulatory agency.
-------
- 2 -
Section I - Monitoring and Reporting
Industrial
The economics of sampling and analysis plus the economics of
review and automated data processing at the present time preclude a
statistical approach to monitoring and self-reporting requirements.
Once enough relevant data has been collected, a statistical approach to
monitoring can be initiated. Thus, engineering judgement has been
exercised in order to describe a program for reasonable minimum
monitoring and self-reporting programs which will provide a nationally
equitable impact and response. The temptation inevitably will be to
require higher frequency sampling and reporting in those industries which
are routinely engaged in analyzing and monitoring their own performance
for internal reporting requirements, such as the petroleum refining,
organic chemicals, and other high technology industries. It must be
emphasized however, that the economic burden does not fall on industry
alone. Automated data processing requirements and man power requirements
for review and report handling within State and Federal agencies must
be controlled, thereby avoiding the problem of requiring more data
than is really needed to provide a reasonable review of treatment
performance.
The determination of effluent limitations must take into considera-
tion the fact that certain pollutants added by the discharger may also
be present in the intake water. In these instances, credit may be
given for that pollutant in establishing the discharge limitation.
Generally, a discharger is not responsible for pollutants entering
with his water supply if he takes water from the same source into which
he is discharging. If his source is other than the receiving stream,
he may be charged with the gross discharge.
Only very rarely will it be necessary to monitor influent values on
the same schedule as effluent values in order to accurately determine
net pollutants discharged. These instances must be held to a minimum
because of the doubling of economic burdens both on industry and govern-
ment. Unless industry specifically requests application of net con-
siderations in writing, or unless it is determined that the difference
between net and gross is of major significance to a discharger, the
permit should be written on a gross basis with no stipulation for in-
fluent values. Where the difference between net and gross application of
effluent guidance is of relatively minor significance but industry re-
quests application of net values, the influent waste loading should be
stipulated based on presentation of existing data by industry (i.e.,
adjust limitation accordingly and write permit in gross terms). Where
application of net values is of great significance to the dischargers
permit, requirements for sampling the influent wasteloadings must be
included. The frequency of analysis of the influent may be l^ss^ttran
that for the discharge if data is shown to substantiate the consistency
of influent analysis.
-------
- 3 -
Pollutants that are removed in the treatment of water in an
industrial facility (e.g., silt removal, filter backwash) may not be
returned to the receiving water. Once a pollutant is removed by the
discharger it may not be reintroduced. In this situation net/gross
considerations will be applied downstream of any pretreatment steps.
Since the thrust of legislative intent has been interpreted as
limiting quantities of pollutants discharged, permit limitations are to
be expressed in kilograms of each pollutant per day. In certain in-
dustrial categories (e.g., mining), effluent limitations must be
expressed in concentration. The lack of control of discharge volume
and its subsequent relation to production volume does not allow an
adequate kilogram per unit of production determination.
Each permit should contain an operating (i.e., monthly) average
as well as a daily maximum.
The time frame selected for the expression of limitations is a
production day. It is, therefore, reasonable to define a sample as
being a daily composite.* This simply means that the effluent stream
in question should be sampled at reasonable intervals during a discharge
day (whether 8 hours or 24 hours). The composite sample should be
representative of what is being discharged. A composite sample is
defined as a combination of individual samples obtained at regular
intervals over a time period. The volume of each individual sample
could be proportional to discharge flow rates or to the sampling interval
Some industrial plants discharge periodically, continuously or on a
controlled basis. All these possibilities must be thoroughly considered.
Minimum requirements are shown for major parameters common to broad
areas (Table I); however, there may be additional parameters of major
importance which should be included in the monitoring requirement
because of a specific situation.
Only those parameters of major significance should be limited and
monitored.
In a few critical situations, the discharger may be required to
analyze the effect of his discharge on the receiving water. This re-
quirement should be separated from the self-monitoring and reporting
requirement as described herein.
Consideration must be given to toxic pollutants. These are not
shown on the chart of parameters to be reported because of the wide
variety of potentially toxic pollutants which could be encountered
* Measurement of some parameters may require a grab sample. A grab
sample is defined as an individual sample collected in less than
fifteen minutes.
-------
- 4 -
Table I
Major Parameters by Broad Industrial Categories
Only parameters of major significance to each specific area will be monitored for reporting purposes
1n order to limit processing and review of irrelevant data. The following table shows major
parameters common to broad areas:
Fecal
Col. BOD COD Metals TSS 011 Temp. pH Flow
Agrarian Products
(Food, forest, tanning, etc.) X X X X
Chemical Plants (Organic,
inorganics, petroleum, textile,
cement, fiberglass, pesticides,
Pharmaceuticals, etc.) XX XX XX
Metal Processing (Steel, Aluminum
motor vehicles, electroplating,
etc.) X XXX XX
Mining and Milling
(Coal, Hard rock, etc.) XX XX
Light Business (Local service
industry, e.g., restaurants, gas
stations, laundries, etc.) X X X
Cooling Water
Power Industry X X
Other XXX
-------
- 5 -
across the width and breadth of industry. Each discharge must be
evaluated for the presence of such other pollutants and, where
appropriate, limits established. Effluent limitations will be estab-
lished in accordance with guidelines stemming from section 307 of the
Water Pollution Control Act as they are promulgated. Industry will
be required to monitor and report on these additional pollutants as
they are identified for specific discharges. Where possible, monitoring
of parameters that are very similar in function should not be required,
e.g., only one Oxygen Demand parameter should be monitored, (i.e.,
6005 or COD). The use of alternative parameters rather than one
specified in guidance may be approved if adequate information showing
the correlation is provided by industry.
Minimum sampling and analysis frequency for process effluents
are shown (Table II). Uncontaminated cooling water discharges should
not be monitored more frequently than the reporting requirement unless
thermal or hydraulic conditions dictate.
The following considerations must be taken into account when
evaluating a minimum sampling and analysis frequency for process effluents:
Compliance Schedule - Unless the discharger has considerable
portion of the abatement facility needed for meeting 1977 requirements
already installed, and/or the effluent is to be specifically regulated
during an interim period, monitoring and reporting requirements should
be held to a minimum. It is suggested that the monitoring requirements
during construction stages of the compliance schedule be less than those
during operation of the treatment facilities. In this situation an in-
frequent sampling and analysis schedule for significant pollutants
should be considered.
Wastewater detention time - Wastewater treatment facilities with
short residence times should be sampled more frequently than wastewater
treatment facilities with long residence times. Extremes of practice should
be taken into consideration. In particular, you will occasionally en-
counter extremely long residence time holding, sedimentation, polishing,
or treatment ponds. Monitoring requirements may be significantly less
frequent for longer residence time facilities if the actual residence
time is established, (e.g., dye tracer studies).
Despite the existence of plans, programs, safeguards and treatment
facilities, any given plant potential for environmental impact in the
event of upset conditions or systemic failures must be taken into
consideration when determining the monitoring and self-reporting re-
quirements. Generally speaking, these considerations include receiving
water quality, plant size, plant age, process technology employed, po-
tential presence of toxic or hazardous materials, and engineering judgment
as to the discharger's capability to fulfill his requirements.
-------
- 6 -
TABLE II
Minimum Sampling and Analysis Frequency
for Process Effluent
Volume, MGD Major Parameters Other Parameters
below 0.05 Once per month Semi-annual
0.05 - 1.0 Once per month Quarterly
1-10 Once per week Once per month
10-50 Three times per week Once per month
Over 50 Daily Once per week
-------
- 7 -
Municipal
The prime objective of this guidance is to identify and place some
limits on the principal elements to consider in establishing minimum
effluent sampling and reporting requirements so that a continuing assess-
ment can be made as to whether effluent permit limitations are being met
at individual municipal wastewater treatment facilities. Recommendations
are provided for flow measuring, sampling, testing and analysis, including
suggested reporting frequencies.
Table III lists minimum numbers of analyses that should be performed
on a plant's effluent on a monthly basis for a range of four plant size
categories. If a percentage removal to determine compliance is required,
the influent must be monitored at the same frequency as the effluent.
Monitoring requirements specified in the permit conditions should be
based at least on these minimum values, but should also take into con-
sideration the facility's present sampling program, the nature of the
receiving waters, the presence of industrial discharges to the facility,
or other controlling influences. The sampling frequency should not be
less than that routinely practiced at the facility if that frequency is
greater than the minimum shown in Table III. The minimum sampling
frequencies and parameters indicated in Table III will necessarily require
modification depending upon the particular effluent limitations specified
in the discharge permit, such as for nutrient control or for control of
industrial wastes discharged to a municipal system. In the latter case,
minimum requirements should be based upon the industrial monitoring guid-
ance provided in this document. In any case, the average monthly value
reported for each type of analysis performed should be the average of
all analyses actually performed of any given type and not limited to the
minimum requirements specified in the permit.
The self-reporting form (Form 3320-1) Figure I provides for reporting
the minimum*, average**, and maximum* values in terms of quantity and
concentration of the analysis performed. The analytical results will be
expressed in concentrations and should be based on composite samples in
order to obtain a representative daily average. The most representative
average concentrations will result from samples collected and composited
according to flow, over a specified period of time. The monthly average
values reported should represent the total volume discharged and should
be calculated from the total loading.
The minimum and maximum values called for on Form 3320-1 should
represent the results of a 24-hour day. In some situations this may be
the result of a single composite analysis while in others it may be the
average of the analysis of three 8-hour composite samples.
* Daily Values
** Monthly Value
-------
Table III
Municipal Wastewater Treatment Facilities
~" Minimum Sampling Frequency
EFI
plant Size (mgd)
Up to 0.99
1 - 4.99
5 - 14.99
15 and greater
£
fe,
Once
each
Wkday . 2
Daily
Daily
Daily
9
in
Q
8
rH
X.
*"'
0)
"d
•H
H
O
•d
O
c
Q)
(0
w
B
cx
"LUENT
\
-------
- 9 -
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
DISCHARGE MONITORING REPORT
FIGURE I
Farm Approved
OMB HO. JM-R007J
J
PERMIT NUMBER
LATITUDE
LONGITUDE
(20-in 122-311 124-asi
REPORTING PERIOD: FROM
1
YEAR
|
MO
|
DAY
124-27) (28
|
YEAR
2>l 130
MO
III
DAY
INSTRUCTIONS
1. Provide dates for period covered by this report in spaces marked "REPORTING PERIOD".
2. Enter reported minimum, average and maximum values under "QUANTITY" and "CONCENTRATION"
in the units specified (or each parameter as appropriate. Do not enter values in boxes containing
asterisks. "AVERAGE" is average computed over actual time discharge iP operating. "MAXIMUM"
and "MINIMUM" are extreme values observed during* the reporting period.
3. Specify the number of analyzed samples that exceed the maximum (and/or minimum «• appropriate)
permit conditions in the columns labeled "No. Ex." If none, enter "O".
4. Specify frequency of analysis for each parameter as No. analyses/No, days. {*.£-, "3/7" t< oquivtt-
lent to 3 enatyaea performed every 7 days.) It continuous enter "CONT. '*
5. Specify sample type f "grab" or " hr. composite") as applicable. If frequency was continuous,
enter "NA".
6. Appropriate ciznature is required on bottom of this form.
7. Remove carbon and retain .copy for your records.
8. Fold alone dotted lines, staple and mail Original to office specified in permit.
132-37) • <64-«e; !ftl-TO» _
PARAMETER
REPORTED
PCHMIT
CONDITION
REPORTED
PERMIT
CONDITION
PERMIT
CONDITION
REPORTED
PERMIT
CONDITION
REPORTED
PERMIT
CONDITION
PERMIT
CONDITION -
REPORTED
PERMIT
CONDITION
REPORTED
PERMIT
CONDITION
NAME OF PRINCIPAL EXECUTIVE OFFICER
LAST FIRST Ml
OB-43) (4«-93) , IB*
MINIMUM
AVERAGE
a t)
MAXIMUM
TITLE OF THE OFFICER
TITLE
IM-esl
UNITS
DATE
VGAR
I
MO
DAY
NO.
EX
<*«-4«) (48-8*1 184-611 «2-e3
MINIMUM
AVERAGE
MAXIMUM
'
UNITS
f certily that t am laatlltar with the Information contained in thie
report and that to the beat at my knowledge and belief luch infor-
mation la true, complete, and accurate.
NO.
EX
FREQUENCY
or
ANALYSIS
SAMPLE
TYPE
'
SIGNATURE OF PRINCIPAL EXECUTIVE
OFFICER OR AUTHORIZED AGENT
EPA Fo.» 3123-1 OO-72)
-------
- 10 -
There is increasing use being made of TOC and COD, especially for
process control purposes. Where enough analyses are conducted to es-
tablish and maintain adequate correlation to BOD, a community may choose
to report analyses of TOC or COD instead of BOD. Details of correlation
procedures will be provided at a later date.
Some types of wastewater treatment facilities, irrespective of size,
may: (1) wholly contain the waste load and never discharge; (2) discharge
continuously; (3) be operated to discharge seasonally; or (4) discharge
on some other controlled basis. Thus, if there is no discharge there
will be monthly reports from some facilities which will be void of data.
Reporting Requirements Submission of Monitoring Forms
Monitoring Forms
Standard forms, "Monitoring Discharge Report" (EPA Form 3320-1)
have been developed to report self-monitoring data provided by dischargers
as a condition of their permits. Identifying information, specific
parameters, effluent limits, and sampling and analyses requirements are
entered by the permit office prior to sending them to the permittee.
Enough forms should be sent to cover the period of time during which the
effluent conditions are applicable. For example, one set of effluent
limits might apply during the first year of a permit before treatment
facilities are constructed while another set of conditions might apply
for three years after construction of facilities. If quarterly entries
on the form were required before construction and semi-annual entries
were required after construction, four reporting forms would be generated
for each discharge to cover the first year's conditions and six forms
would be produced for the remainder of the conditions. A similar
procedure would apply if there were an increase in sampling frequency
shortly before and after construction of treatment facilities.
Each Discharge Monitoring Report form may be used for the combined
effluent measurements of an entire facility, combinations of selected
outfalls, or a single outfall. The form is on two-part paper consisting
of an original and a copy and is so designed that the original may be
folded, stapled and sent to the permit reviewing office. There is space
on the reverse of the form for any comments the discharger may wish to
include. There is a complete computerized processing system to auto-
matically process this form.
In some cases, States having authorized NPDES permit programs may
wish to utilize their own form. This is considered acceptable under the
NPDES Permit Program as long as such non-standard forms are approved by
EPA and contain all of the requested data elements reported on the
standard NPDES form.
-------
- 11 -
Reporting Schedule
Monitoring Discharge Report Forms will be required to be filed
on a regular basis with EPA Regional Offices or approved State Offices.
Sufficient time should be given for the reporting period in order to
allow for completion and mailing of forms. Reports will be required
at the following frequency:
Quarterly - Any discharge greater than 1 mgd flow, any
discharge classified as major and/or toxic, and all
municipal treatment plants.
Semi-annually - Any industrial discharge less than 1.0 mgd.
Excessive Pollutant Discharges
Non-compliance to extreme value conditions (maximum and minimum
quantities) might indicate a serious situation, the response time
obtained from a self-reporting program is considered too long to be
meaningful. In order to be responsive to exceptionally high pollutant
loads an "Excessive Pollutant Discharge" response system will be used.
Since the extreme value condition(s) (e.g., maximum and/or minimum)
indicate out-of-control circumstances, the permittee will be instructed
in the special conditions of the permit to notify the Regional
Administrator or the Director of any approved State Agency immediately
of the occurrence of the noncompliance. The permittee shall take all
reasonable steps to minimize any adverse impact to navigable waters
resulting from noncompliance with any effluent limitations specified
in the permit, including such accelerated or additional monitoring as
necessary to determine the nature and impact of the noncomplying
discharge.
-------
- 12 -
Section II
Data Management
I. Introduction
Any large monitoring program as has been described in Section I
implies large amounts of data being generated. In order to successfully
manage this quantity of data, automated data processing (ADP) techniques
must be employed. However, several considerations must be given to the
ADP system to be used to obtain a system which provides the most benefits
for the least cost and still satisfies the requirements of a monitoring
discharge program.
A description of the system that has been designed to handle the
requirements of the permit program's self-reporting of monitoring
analyses consists of the following:
A. Description of Data Flow
How reports and data flow between the EPA and the States and the
interface between the office operating the ADP system and the system
itself.
B. Resource Status and Requirements
What is required in the way of personnel and equipment (especially
in State offices) compared to what is currently available.
C. System Description
The computer software available to aid in operation of the system.
D. Cost Considerations
An accounting of expected operating costs (exclusive of personnel).
II. System Description
A. Description of Data Flow:
The way in which data flows is dependent on where the data
processing is being conducted. If the State office conducts
its own data processing (as is highly recommended) the
flow is quite straightforward. A diagram of data flow
under this situation is presented as Version A in Figure II.
It contrasts sharply with the complications that develop where
EPA must handle the data processing for a State which is adminis-
tering the program. This is presented as Version B in Figure III.
As will be noted on the diagram there are options available at
two flow points. These are at the beginning when the form is
initially sent to the permittee and again when the form is re-
turned to the reviewing office. These options are left to the
particular EPA Regions and States involved to resolve which
option is actually used. There is, of course, a Version C
-------
Figure II
Flow Diagram for Processing of Discharge Monitoring Report
When State has Permit Authority and Conducts Data Processing(Version A)
State sends monitoring
'reporting form and
requirements to permittee
Permittee completes forms
and sends them into State
office according to required
reporting frequency
State logs in forms,
keypunches data and
enters it into
central computerized
data system via
remote terminal
EPA executes
update program
weekly in
order to load
data onto
permanent
data file
State verifies
data entered
into computer
and corrects
errors
\
•State executes
program monthly
which computes
and prints out
exceptions to
reporting
requirements
and deviation
from permit
conditions
_ -^
EPA and others
retrieve discharge
monitoring data as
desired either
separately or in
conjunction with
data from other
sources (e.g.,
application,
abatement schedule,
etc.
'EPA executes compliance
routine on exceptions
as required either on
a national or state by
state basis
-------
Figure III
Flow Diagram for Processing of Discharge Monitoring Report
When State has Permit Authority and EPA Conducts Data Processing (Version B)
State sends monitoring
requirements to EPA
Regional Office
or
State manually enters
requirements and permit
conditions on Discharge
Monitoring Report and
sends to Permittee
EPA produces monitoring
forms by ADP and sends
to Permittee
(Option used to be
decided between EPA
Regional Office
and State)
'Permittee completes forms
and sends them to State
according to required
frequency
or
Permittee completes forms
and sends one set to
State and duplicate set
to EPA according to
required frequency
or
Permittee completes forms
and sends them to EPA
according to required
frequency
-*©
(Option used to be decided
between EPA Regional Office
and State)
-------
Figure III(Con't)
.State forwards copy
of report to EPA
EPA makes a copy
and sends original
to State
EPA logs in forms ,
keypunches data and
enters into central
computerized data
system via remote
terminal
EPA executes update
program weekly in
order to load data
onto permanent data
file
EPA verifies
data entered
into computer
and corrects
errors
EPA executes exception routine monthly
which computes and printout exceptions
to reporting requirements and deviations
from permit conditions
EPA sends copy of
exception report
to State
in
i
xk.
EPA and others retrieve discharge
monitoring data as desired either
separately or in conjunction with
data from other sources (e.g.,
application, abatement schedule, etc.
-------
- 16 -
(not shown) which is similar to version A where EPA is adminis-
tering the program as well as conducting the data processing.
The main feature of the data flow described above is that the
data reflects the minimum requirements set by EPA through the use
of standard forms and that it is entered into a centralized com-
puter processing system over remote terminals. In this way many
interested parties may review the same data from one central fa-
cility. If some State offices do not use the standard NPDES
Discharge Monitoring Report forms (EPA Form 3320-1) but their
own EPA approved forms containing the minimum data requirements,
it will be necessary to either transfer the applicable data to the
standard form or to develop a computerized conversion program
to arrange the data in the proper format before it is processed
by the ADP system described below.
In summary, three versions (A-C) of data flow have been presented.
It is very important that each EPA Regional office and States
where applicable decide on which version and options are to be
utilized in each particular situation before any self-monitoring
system is implemented. Maximum consideration should be given
to working out arrangements which simplify the amount of data
handling required while maintaining program integrity.
B. Resource Status and Requirements
The minimum resource that is required of any office which plans
to utilize the ADP system described below is one basic low-speed
(IBM 2741 type) configuration and one basic configured medium-
speed (Data 100) remote computer terminal. These terminals
are briefly described in Table IV with their approximate monthly
rental costs. The low-speed terminal is necessary for practical
entering of retrieval requests, some data entry, and printing of
output. A medium-speed terminal is necessary for reading in any
significant amount of data from punched cards or magnetic tape,
printing large amounts of output, and preparing reporting forms
to be sent out.
Table V lists those States that currently are using the EPA
central computer system and currently have at least a low-
speed terminal. Note that only three states currently have medium-
speed terminals. All EPA Regions have sufficient equipment to
accomplish the required processing.
Personnel required to operate the monitoring ADP system should
consist of at least one subprofessional data processing clerk and
one professional level computer specialist.
-------
- 17 -
Table IV
Uses and Cost of Time Sharing Terminals
Type Use Cost
Low-Speed Minimal input and $100/mo (basic
(typewriter type) output such as $250/mo (with mag
(15 characters/sec.) with MICS. Good card or cassett)
for making re-
trieval requests
of data system
Medium-Speed Required for read- $900/mo (basic)
(200-400 lines/sec.) ing in any sig- 1800/mo (with mag
nificant amount tape and some local
of data (i.e., computing capability)
as from punched
cards.) Needed
for any sig-
nificant amount
of data retrieval
and for producing
input to self-
monitoring re-
ports to send to
permi ttee
-------
- 18 -
Table V
States Presently Having Remote Computer Terminals
State Type of Terminal
State Low-Speed Medium Speed
Ari zona X
Arkansas X
California X
Colorado X
Connecticut X X
Delaware X
District of Columbia X
Florida X
Idaho X
Illinois X
Indiana X
Kansas X
Kentucky X
Maryland X
Massachusetts X
Michigan X
Missouri X
Montana X
Nebraska X
Nevada X X
New Jersey X
New Mexico X
New York X
North Carolina X
Ohio X
Oklahoma X
Oregon X
Pennsylvania X
South Carolina X
South Dakota X
Tennessee X
Texas X
Virginia X
Washington X X
West Virginia X
Wisconsin X
-------
- 19 -
C. System Description
Computer software has been developed to assist in processing
of self-monitoring data. Although the various programs
are designed to process the standard NPDES Discharge
Monitoring Report, it could also be used to some degree
with data from approved non-standard reports arranged in the
proper format for entry into the main data file.
The computerized monitoring system is an independently operating
processor which is tied in with the General Point Source File
{GPSF). In other words, the monitoring system works against
the data but the data are stored in GPSF.' All the general
retrieval capability of GPSF will consequently be available
on the self-monitoring data processed.
An outline of the monitoring data processing system is presented
in Figure IV. Initial monitoring requirements are entered on
punched cards which automatically enters the monitoring con-
ditions on the standard form, produces the required number of
reports and mailing labels, and initializes the file in order to
check for exceptions on reports received and non-compliance with
permit conditions as they occur. After reports are received with
self-reported monitoring data, they are entered into the system.
The system then automatically checks the data for validity and
supplies any exception to permit conditions as well as a list
of late filers.
D. Cost Considerations
Costs for processing of monitoring data (exclusive of personnel)
are presented in Table VI. The first group of costs cover
producing the forms and initializing the file. The second
group of costs cover processing of forms once they are received
back from the discharger. The total monthly cost of $5,000
is based on 5,000 facilities with two discharges each reporting
monthly on six parameters per discharge. The costs of processing
are, therefore, approximately one dollar per facility or fifty
cents per discharge. It should be noted that no cost is assigned
to disc pack storage. This is because there are no charges for
mounting off-line disc packs. It is not considered necessary that
A description of GPSF is available from the U.S. Environmental
Protection Agency, Information Access and User Assistance Branch,
Monitoring and Data Support Division, Office of Water Programs,
Washington, D.C. 20460
-------
•Figure IV
- {Monitoring Flow -
I
j Keypunch
EPA Request
F
Monitoring
System
Report
Writer
V
General
Point
Source
File
Discharge
Monitoring
Report
Edit Error
Listing
ro
o
Discharge
Monitoring
Report
Monitoring
System
Report
Writer
•Applicant Input
Exception
Report
L.ate Report
-------
- 21 -
Quanti ty/
Year
700,000
70,000
6 hrs.
1 Disc Pack
Cost
per/month
$ 15.00
175.00
75.00
0
Cost
per/year
$ 175.00
2,100.00
900.00
0
Table VI
Estimate of Automated Data Processing Costs of Self-Monitoring Program
(Basis of Costs: 5,000 facilities with two discharges (outfalls) each
reporting monthly on six (6) parameters per outfall)
Initial Set Up (12 reports per discharge per year)
Item
Print Lines
Punched Cards
Computer Time
$265.00
Processing Returned Reports
Item
Print Lines*
Punched Cards
Computer Time
Data Storage (Off-line) 1 Disc Pack
$ 4503
Total Cost/month $ 4,768
Total Cost/year $57,331
* Assumes one-third exceptions reported
$ 3,175.00
Quantity/
Year
10,000
120,000
6 hrs.
1 Disc Pack
Cost
per/month
$ 3
3600
900
0
Cost
per/year
$ 36
43,320
10,800
0
$54,156
-------
- 22 -
vast amounts of data be kept on-line at all times at a greatly
increased cost. The off-line mode still allows a minimum
four hour turnaround with overnight service obtainable with
high reliability. These turnaround times are certainly
sufficient for any intended use of the system.
The above are the types of cost that should be considered in
conjunction with assigning monitoring reporting requirements
and use of ADP systems to process self-mom'toring data. Since
it costs both in time and money approximately the same to process
a minor discharger as a major discharger, it is very important
for the reviewing offices to process reports according to a
pre-established priority in order to achieve the greater benefit
for the resource available.
------- |