vvEPA
United States
Environmental Protection
Agency
Water
Office of Marine
and Estuanne Protection
Washington DC 20460
tPA 430/09 88 002
Sc-ptemtici 1987
Framework for 301 (h)
Monitoring Programs
60
nco
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U.S. EPA Contract No. 68-01-6938
TC-3953-31
Final Report
FRAMEWORK FOR 301(h) MONITORING PROGRAMS
for
Marine Operations Division
Office of Marine and Estuarine Protection
U.S. Environmental Protection Agency
Washington, DC 20460
September 1987
by
Tetra Tech, Inc.
11820 Northup Way, Suite 100
Bellevue, Washington 98005
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CONTENTS
P aa e
LIST OF FIGURES iv
LIST OF TABLES v
INTRODUCTION 1
BACKGROUND AND PURPOSE 1
OVERVIEW 2
Administration 2
Guidance 2
Program Coniponent
PROGRAM DESIGN S
PERMIT SPECIFICATIONS 10
MONITORING OBJECTIVES 12
General Requirements 13
Biological Monitoring Program 15
Water Quality Monitoring Program 16
Effluent Monitoring Program 17
STUDY DESIGN 18
Sampling Locations 18
Sampling Frequency 19
Replication and Compositing Schemes 19
Sampling Protocols 20
Analytical Methods 20
Data Reporting Requirements 20
MONITORING PROGRAM IMPLEMENTATION 22
SAMPLING AND REPORTING REQUIREMENTS 22
Sampling 22
Reporting 24
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ODES DATA ENTRY AND QUALITY ASS( }RANCE 24
Data Entry
Quality Assurance
ODES DATA ANALYSIS 31
MONITORING DATA EVALUATIONS 35
REGULATORY AND PERMIT COMPLIANCE 35
EFFECTIVENESS OF 301(h) MONITORING PROGRAMS 38
OVERALL 301(h) PROGRAM EVALUATIONS 40
PROGRAM MODIFICATIONS
111
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FIGURES
Number
1 301(h) monitoring orogram framework
2 Design of a 301(h) monitoring program 9
3 301(h) program implementation 23
4 301(h) Permit Monitoring: Scope of ODES 25
5 Procedure for submittal of ODES data 27
6 ODES data tyDes 32
7 30i(n) mon ltQrlng ata evaluation
8 301(h) monitoring program review 42
iv
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TABLES
Number
1 301(h) guidance documents
2 Regulatory requirements for a 301(h) monitoring program 14
3 ODES analytical and decision-support tools 33
V
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I NTROOUCT ION
BACKGROUND AND PURPOSE
Publicly owned treatment works (POTWs) that discharge wastewater into
marine waters may be granted a waiver from the requirement for secondary
treatment under Section- 301(h) o,f the Clean Water Act of 1977. The waiver
is issued as part of the facility’s National Pollutant Discharge Elimination
System (NPDES) permit. The permits specify effluent limitations plus
effluent samole types and samoling frecuencies needed to assess discharce’
ccmol ance witn oermit ccnd c.is
To ensure compliance with the terms and conditions of the 301(h)
modified NPDES permit [ i.e., 301(h) permit] and other applicable water
quality requirements, each POTW must conduct a monitoring program. The
goals of the monitoring program are to assess the impact of the discharge on
marine biota and water quality, and to determine concentrations of toxic
pollutants in the treated effluent and in the sediments of the receiving
environment.
This document is intended to serve as an introduction to 301(h)
monitoring programs. It describes the framework of the program by reviewing
the three major stages in the monitoring process:
• Program design
• Program implementation
• Program evaluation and modification.
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OVER’I I EW
Admin-i stration
The 301(h) marine monitoring program is administered nationaiiy through
the U.S. Environmental Protection Agency (EPA) Office of Marine and Estuarine
Protection (OMEP), Marine Operations Division. The program is administered
regionally through the Water Management Divisions of U.S. EPA Regions I, II,
III, I V, IX, and X. The Marine Operations Division holds primary responsi-
bility for providing technical guidance on monitoring program development:
managing the Ocean Data Evaluat on System (ODES). a comouter based s’ista ’
2’/ OCed :3r t e ianaceme i: :ric f ar’ne ioni::r ig :a a :
assessing program effectiveness from a national perspective. The U.S. E?A
regional offices hold primary responsibility for evaluating all 301(h)
applications; issuing 301(h) permits to individual POIWs; overseeing
compliance with permit criteria (including implementation of the monitoring
program); and interacting with regional, state, and local government
agencies.
Guidance
The U.S. EPA Office of Research and Development (ORD) supports both the
Marine Operations Division and the regional offices by providing technical
guidance in the review of applications, and assisting in the analysis of
monitoring data. ORD has assisted the 301(h) monitoring program by providing
very strong guidance in areas such as the development of coral reef moni-
toring protocols for Region II, the use of caged mussel transplants to
assess bioaccumulation and impacts at discharge outfalls, and the selection
and critique of statistical design used in sampling analysis.
Representatives from the Marine Operations Division, regional offices,
and ORD are members of the 301(h) Task Force, which was formed to coordinate
implementation of the 301(h) program. Based on 3010j) Task Force recom-
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mendations, the decision-making authority of the U.S. EPA Administrator na3
delegated to the Regional Administrators. By Cune 1983, all six regions had
accepted the delegated respons biiity for all 301(h)-permitted o scha’ ers.
with the Marine Operations Division retaining joint responsibility for the
first 30 dischargers that applied for a 301(h) modification. The task force
continues to provide technical assistance evaiQating 301(h) pp cat icrs.
tentatiVe decision documents, and ior.itor ng guidance documents.
To ensure that 301(h) permits ar& consistent with local water quahzy
standards, all applications for 301(h) modifications are reviewed by the
relevant state or interstate agencies. Section 301(h) permits cannot be
issued until state certification or concurrence is granted or waived.
Severai tecn’cai :uica ce :c te ; ve : e - v ’coec - - -
program to assist both the permittee and the regions :n the design, irnp e rer_
tation, and evaluation of individual monitoring plans. For example, 301(h)
applicants must provide U.S. EPA with sufficient information on quality
assurance/quality control (QA/QC) procedures to document compliance with
accepted scientific practice. A guidance document was produced to ensure
that data collected during 301(h) monitoring programs are of comparable and
known quality.
Because each monitoring plan is permit-specific, the guidance documents
have been widely reviewed to ensure that they are responsive to the objec-
tives of individual programs. The general subjects for which 301(h)
technical guidance documents have been produced are listed in Table 1.
Program Components
The major components of the 301(h) monitoring program are outlined in
Figure 1. The basis of the framework is the 301(h) permit, in which all
discharge limits, monitoring variables, sampling protocols, analytical
methods, and reporting requirements are specified. U.S. EPA regional
offices, state agencies, dischargers, and other interested parties partici-
pate in developing the monitoring program during the permitting process.
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TABLE 1. 301(h) GUIDANCE DOCUMENTS
1) Revised Section 301(h) Tecnnical Suo ort Document (1982)
2) Design of 301(h) Monitoring Programs for Municioal astewa e Discnar:es
Marine aters (1982)
3) Ecological [ moacts of Sev age Discharges on Coral ReeF Communities
4) Summary of U.S. EPA—Aporovea Methods, Standard Metnods, ana •Jt ier u’Oäfl’
301(h) Monitoring Variables (1985)
5) ODES User’s Guide (1985)
6) Recommended Biological Indices for 301(h) Monitoring Programs (1985)
7) Bioaccumulation Monitoring Guidance
1 Est matinc hp Por. n ’. .i r B rc’jmijlar cr, nf - nr - / De’,
301(h) st c’aes J’scr. r ec nt ar:r. ma E jar ie
2) Selection of Target Spec es ana Reviev f , vailable B oaccurria:
Vol I & Vol I I (1985)
3) Recommended Analytical Detection Limits (1985)
4) Analytical Methods for U.S. EPA Priority Pollutants and 301(h) Pest c ices
in Tissues from Estuarine and Marine Organisms (1986)
5) Strategies for Sample Replication and Compositirig (1987)
8) Analytical Methods for U.S. EPA Priority Pollutants and 301(h) Pesticides in
Estuaririe and Marine Sediments (1986)
9) Evaluation of Survey Positioning Methods for Nearshore Marine ana Escuar rie
Waters (1986)
10) Quality Assurance/Quality Control (QA/QC) for 301(h) Monitoring Programs:
Guidance on Field and Laboratory Methods (1986)
11) ODES Data Submissions Manual (1986)
12) ODES User Guide: Supplement A, Description and Use of Ocean Data Evaluation
System (ODES) Tools (1986)
13) The Quality Assurance Process for ODES Data (1986)
14) Technical Evaluation and Quality Assurance Procedures for the Ocean Data
Evaluation System (ODES) (1986)
15) Guidance for Conducting Fish Liver Histopathology Studies during 301(h) Monitoring
(1987)
16) Technical Support Document for ODES Statistical Power Analysis (1987)
17) A Simplified Deposifion Calculation for Organic Accumulation Near Marine Outfalls
(1987)
18) Framework for 301(h) Monitoring Programs (1987)
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Figure 1. 301(h) monitoring program framework.
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Under the law, the monitoring program must provide data for- evaluating the
;rnoact of the disc ’ar9e on marine biota, for demonstratinc c rnokance , ::‘
applicable . ater quality standards, and for determining concentrations of
toxic substances iii the effluent. Monitorin program design is O1SCLISS2d in
derail in the followinc chapter.
The monitoring program is mp]ementeo after issuance of :he 3Oith;
permit. Monitoring reports must be submitted to the Regional administrator
monthly, quarterly, twice yearly, or annually, as specified in the permit.
Monitoring data must also be submitted for entry into ODES, a computerized
database providing analytical and decision—support tools usea to evaluate
marine and _estuarine environmental impacts. Data in ODES are a aiiabie to
A heaccjar:e’ , rec ‘ ices, ORD, re r—--
oicers, aria ar ous yover ment :onr:acrors. ens e :ec :3
is available for data entry, data analysis,, and OA/QC procecures. ODES is
discussed in detail in the chapter called “Monitoring Program Iniplementa—
tion.”
Data from an individual monitoring program can be used for several
basic purposes:
• Assess sampling and analytical procedures
• Determine whether objectives of the program have been met
• Assess effects of the effluent on marin e biota and water
quality
• Determine compliance with terms and conditions of the per-mit.
From a national perspective, collective data from all the monitoring programs
can be reviewed to perform additional evaluations:
• Identify large—scale environmental impacts and trends
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• Compare individual monitoring programs to determine the most
effective prcgram designs
• Support ecisions concerning permit issuance or renewal
The monitoring cata can also oe usao to assess zhe efFecti ienes of my
toxics control program trat may be in place. Inese programs r3CJ on
identifying and reducing sources of pollutants by requiring industries to
7 pretreat wastes that are discharged into the municipal sewers. The pre-
treatment program is not applicable to smal-l dischargers unless a separate
state program requires their participation. The evaluation of monitoring
results to determine individual and national program effectiveness s
discussed in detail in the chaoter ‘a1 1 ed “Monitor ng Proarem Evaluat cn
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PROGRA’l DES GN
Section 301(h) monitoring programs are designed :o adcress the fo1 ’.n g
three general -egulatory ecuirements established under 0 CFR 125.62:
• Document short- and long-term effects of the discharge on
receiving waters, sediments, biota, and beneficial uses of
the receiving water
• Determine : rrD’anc2 ifth the terms nd ‘on itons of 30i h
er ni :
• Assess the effectiveness of toxics control programs.
Although the scope and intensity of specific monitoring programs can differ
considerably, most are designed to measure various characteristics of the
discharge and the receiving environment. Monitoring of the P01W may include
evaluations of influent, effluent, and sludge. Monitoring of the receiving
environment may include evaluations of water quality, sediments, and
biological communities.
This section provides an overview of how 301(h) monitoring programs are
designed. As shown in Figure 2, this design process comprises the following
major steps:
• Specify the terms and conditions of the 301(h) permit
• Develop monitoring objectives to address the above
specifications and regulatory requirements
• Design a study to achieve the monitoring objectives.
Each of these steps is described in detail below.
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4-
301(h) MONITORING
GUIDANCE DOCUMENTS
EVALUATE
EXISTING
DATA
PREDICT
ENVIRONMENTAL
EFFECTS
*7
CONSIDER
REGULATORY
REQUIREMENTS
SPECIFY TERMS
AND CONDITIONS OF
THE 30 1(h) PERMIT
I
0
*7
DEVELOP MONITORING
OBJECTIVES
sip
DESIGN A
MONITORING PLAN
4-
*7
INCORPORATE
MONITORING PROGRAM
INTO THE 301(h) PERMIT
Figure 2. Design of a 301(h) monitoring program.
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PERMIT SPECIFICATIONS
The 301(h) permit provides the basis for each mon1tori rogra i 5
specifying the variables that should be monitored, and tne corres;orc rig
regulatory criteria. The first step in the program design rocess is :c
review the permit and develop a list of variables to be included in the
monitoring program. The specifications of each 301(h) permit arc influenced
by at least three major kinds of information (Figure 2):
• E-xisting data on effluent characteristics and environnieltal
:cndi t cr.s
•, Predicted environmental effects of the discharge
• Existing federal, state, or other applicable requirements.
All of this information is evaluated and synthesized when the permit is
developed.
Existing data on effluent characteristics and environmental cond t ons
are used to define the important aspects of each discharge and receiving
environment. These aspects may include the following:
• Flow of effluent
- Magnitude of flow
- Variations in flow
• Chemical composition of effluent
- Problem chemicals
- Variations in composition
• Toxicity of effluent
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• Backcrr,und environmenta 1 conditions
- Current re ime
- Bathvmetry
- Characteristics of bottcm sediments
- indigenous biological communit es
• Critical environmental conditions
- Unusual oceanographic conditions
- Sensitive environmental habitats
- !ens ive scecies
:c i:ca’ ’ —: :anz ::eces.
Because these aspects can vary widely among dischargers, 301(h) monitoring
programs are designed to address discharge-specific problems. Therefore,
the programs cannot be generic in content.
Most of the existing data on the effluent and receiving environment are
presented by each discharger in the application for a 301(h) permit.
Additional information usually is collected by U.S. EPA or its contractor
when the application is being reviewed, or when the permit and monitoring
program are being developed.
Predicted environmental effects of each discharge are used to identify
key variables that should be addressed in the 301(h) permit. For example,
if substantial deposition of particulate material is predicted near an
outfall, the permit may specify that evaluations of benthic macroinverte-
brates be conducted to determine discharge-related effects on the organisms
that live in close association with the sediment. If the discharge includes
chemicals t ät ôi ld lead to bicaccurnulation (e.g., mercury, chlorinated
hydrocarbons)•or liver disease (e.g., polycyclic aromatic hydrocarbons) near
the outfall, the permit may specify that surveys be conducted for tissue
contamination and liver histopathology in demersal fishes.
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Each 301(h) permit must be consistent with existing federal, state, or
other applicable requirements. The primary federal regulations are ;et
forth in Section 402 of the Clean Water Act, and apply to all aiscnarges of
pollutants to navigable waters of the U.S. These regulations spec fj
limitations orimarily for effluents and, in some cases, ec’.iirements far’
receiving water. State regulations vary widely, but requenc J include
limitations for pH. dissolved oxygen, coliform bacteria. arc 3.iS0eflCC
solids (or. a surrogate) in the receiving water. State requirements often
are expressed as a maximum allowable pollutant concentration, a maximUm
allowable deviation from background concentrations, a statistically
significant difference between stations, or as a regulation against harm to
biata or degradation of beneficial uses of the water body. ifl some cases.
r Tents cther thcse at t’ e fede ’a 1 r state’e’.’el :‘ 5c r r,hi .ki
a a ar c s ’ar . C afl . :- q -at-
establishes requirements relating to wastewater discharges in tne ew York
Harbor area. In California, basin plans developed by regional boards or
agencies contain requirements in addition to those of the state.
To ensure that each 301(h) permit is consistent with all applicable
regulatory requirements, all permit applications are reviewed by the
appropriate federal, state, or interstate agencies. As noted earlier,
301(h) permits cannot be issued until state certification or concurrence is
granted or waived.
Once the terms and conditions of a 301(h) permit have been established,
a monitoring program is designed tq document compliance with the specifica-
tions of the permit. The monitoring program is developed in conjunction
with all appropriate federal and state agencies and is included as part of
the 301(h) permit.
MONITORING OBJECTIVES
After the specifications of the permit have been reviewed and sum-
marized, the fundamental design of the monitoring program is established by
defining the objectives. The overall monitoring objectives are defined to
determine compliance with NP ES permit conditions, document effects of the
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discharge on the receiving water quality and biota, and assess the effective-
ness of pretreatment programs to control toxic inputs.
To meet the monitoring objectives, each 301(h) permit defines SOEC1C
relevant requirements which must be 4 ncorporated into the monitorinqprogram
aswell as general requirements listed in, 40 CR i25. 2. These re u rernents
are categorized into four general areas:
• General requirements
• Biological monitoring program
• Water auality io ’i c cr m
• Effluent monitoring program.
The regulatory requirements associated with each category are outlined in
Table 2. The primary objectives of the monitoring program are developed
from these requirements. Objectives are also developed from permit
limitations that specify maximum or minimum values (e.g., concentrations)
for variables measured in the discharge.
General Requirements
The general monitoring requirements stipulate collection of biological,
water quality, and effluent monitoring data to assess permit compliance and
evaluate the impact of the discharge on marine biota. The general require-
ments also specify that sampling and analytical techniques, frequency and
extent of the monitoring, arid availability of resources necessary to meet
the program objectives be established. These factors are an essential part
of the study design and ensure that specific objectives of the monitoring
program can be met. (See the next section on study design.)
A critical aspect of determining compliance with the general limitations
of a 301(h) permit is the specification of testable hypotheses. These
hypotheses focus the monitoring activities so that the studies are conducted
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TABLE 2. • EGUL.ATCR’r’ E UIRE ’1ENTS FOR A MONITORING PROGRAM
General Requirements:
- Provide data to evaluate the impact of the discharge on mar ne b ota.
- Demonstrate compliance with water quality standards.
- Measure toxic substances in the discharge.
- Describe sanipling and analytical techniques, quality control procedures,
and sampling locations and schedules.
- Demonstrate that resources are available to carry out the program for the
life of the permit.
- e:er ie r enc’j anc ex aiz f t. e on: rnç r çra. i.
Biological Monitoring Program:
- Conduct periodic surveys of biological communities most likely to be
affected by the discharge and communities at reference sites.
- Conduct periodic determinations of the accumulation of toxic pollutants
in organisms and examine potential adverse effects.
- Measure the accumulation of toxic pollutants in the sediments in conjunction
with the biological and water quality surveys.
- Conduct periodic assessments of the conditions and productivity of commercial
or recreational fisheries.
- Demonstrate that the discharge has met all requirements of 40 CFR 125.61,
including attainment and maintenance of water quality to assure protection
of public water supplies; to assure protection of a balanced, indigenous
population of shellfish, fish, and wildlife; and to allow recreational
activities.
Water Quality Monitoring Program:
- Provide adequate data for evaluating compliance with applicable water
quality standards.
- Measure the concentrations of toxic pollutants expected to be present in
the discharge.
Effluent Monitoring Program:
- Provide quantitative and qualitative data that measure toxic substances
in the effluent and the effectiveness of the toxic control program.
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efficiently and results are useful for evaluating statistically s gniF;cant
differences between areas. In n ost cases. multiple testable yootheses •ii
be required for each monitoring . ogram objective. Examples of testable
hypotheses for each kind of monitoring data are discussed ifl the following
three sections.
Biological Monitorinc Proaram
The biological requirements specify that the monitoring program provide
data to determine the effects of the discharge on biological communities, the
accumulation of toxic pollutants in organisms and sediments. and the
productivity of commercial and recreational fisheries. The mon toring
rocram must o r’Dvide dat to emonstrete the rotect’cn f : i’ ‘ tar
tie . a. :e ance :a ance . i:encus :couia: ns
fish, and other wildlife; and the maintenance of conditions allowing for
recreational activities.
Therefore, biological monitoring programs are composed of multiple
monitoring objectives. Each of these objectives also involves relatively
complex comparisons of multiple biological measurements near the discharge.
Moreover, because of a lack of absolute numerical criteria, the evaluation
of permit compliance is generally accomplished by comparing biological
conditions near the discharge with conditions at a reference site. These
comparisons are usually conducted by statistical tests. Therefore, the
monitoring objectives are translated into a series of testable hypotheses
that are used to guide monitoring program design as well as subsequent data
analyses.
The testable hypotheses are generally expressed as null hypotheses that
compare biological conditions at various monitoring stations (e.g., there
are no differences in the monitored variables at discharge and reference
areas).
Two examples of null hypotheses related to the biological monitoring
program are described below.
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• The total abundance of benthic macroinvertebrates coes not
differ between a samoling station near the outfal and a
reference s:at on.
This hypothesis addresses whether one biological variable (‘ e total
aoundance) is affeetea cy z e iscnar;e. lany s mi ar :es:
(e.g., for - -individual soec es or other biologi al ccrnrnunitj a es • :
also be formed to determine whether the monitoring objectives are being met.
• The concentration of a toxic pollutant in sediments does not
correlate with the prevalence of liver lesions in demersal
fishes.
-.i3 v thes s c: s:es net e the ec: uiat:r ::ec’
in sediments near the uiscnarge is associated with aisease revaience n
fishes. The results of the monitoring and subsequent tests of this hypo-
thesis are one element that can be used to infer whether the discharge is
causing adverse effects on indigenous biota.
The first hypothesis directs the POTW to sample benthic invertebrates
near the outfall and at a reference area with sufficient replication to sta-
tistically discriminate a difference in total abundance between the two
sites by using an analysis of variance (ANOVA) test. The results of the
ANOVA would then be used as one of several measures to determine whether a
marine community near the outfall was being degraded. The second hypothesis
directs the P01W to measure the concentration of toxic pollutants in the
sediment in conjunction with fish trawis at stations located along a gradient
of increasing distance from the outfall. In a similar manner the many
hypotheses formed direct the design of the overall biological monitoring
program.
Water Quality Monitoring Program
The water quality requirements specify that the monitoring program
provide data for evaluating compliance with applicable water quality
standards and documenting whether toxic pollutants associated with the
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discharge are present in the water. The objectives associated with the
water qual-ity requirements are more easily tested than the b io gicai
objectives, but rely on several key assumptions, such as the foilowing:
• Toxic pollutants found in the effluent are not und at
concentrations above water quality criteria in tne recv
water because of the large dilution factor.
• The sampling and analytical methods used to test the
hypothesis give detection limits significantly below the
water quality criteria in both the effluent and the receiving
water.
T jaz:s . : ese :c ec::’ s. : ic: r i : ‘- ‘ ‘am :r)L.:
analysis for a wide range of toxic pollutants and receiving water analysis
for all compounds found in the effluent. Testable hypotheses would be
developed to determine the probability of finding a compound in the effluent
and the frequency with which the effluent must be analyzed to ensure that
its composition has not changed.
Effluent Monitoring Program
The effluent requirements specify that the monitoring provide quali-
tative and quantitative data on toxic substances in the effluent and on the
effectiveness of the pretreatment program. The following are examples of
hypotheses associated with the objectives of effluent monitoring:
• Compounds not detected in one monthly 24-h composite sample
will not be detected at any other time during that month.
• Decreases in the concentration of a compound in the effluent
are associated with increases in the amount of pretreatment.
Because of the inherent variability of the effluent, the relevant hypotheses
are difficult to test without extensive sampling. The monitoring design
generally uses compositing schemes to help reduce this short-term variability
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and enable comparisons of average concentrations. The use of compositing an
reolication is discussed in the next section.
STUDY DESIGN
Once the specific objectives and associated testable h:iootheses of a
301(h) monitoring program have been determined, a detailed monitor g ?a
is designed. The cost of the plan should be reasonable, and the data should
be of sufficient quality to determine compliance with permit limitat ons. to
test the hypotheses that are developed from certain objectives, and for use
in any other kind of analysis required to address a specific objective. A
variety of 301(h) monitoring guidance documents have been develooed to
assist the des g.i of e ec ve mcnitoring plans ‘ab e ‘
Each 301(h) monitoring plan includes the following major elements:
• Sampling locations
• Sampling frequency
• Replication and compositing schemes
• Sampling protocols
• Analytical methods
O Data reporting requirements.
After the details of each plan have been reviewed and approved by U.S. EPA
and other appropriate federal and state agencies, they are included as part
of the 301(h) permit.
Sampling Locations
Influent samples should be collected downstream from coarse screens or
grit chambers and before any further treatment. Effluent samples should be
collected downstream from chlorination or disinf ction units. Within the
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receiving environment, stations should generally be located within the zone
of initial dilution (ZID). at the ZID boundary. at near eid stations. anc
at a reference area. This station-location scheme allows environmental
effects of the discharge_ to be evaluated at increasing distances from the
discharge point (i.e.. gradient analysis).
Sainol inc Frecue cv
The appropriate sampling frequency varies from program to program. For
large discharges containing substantial quantities of toxic chemicals and
flowing into sensitive receiving environments, sampling frequencies may need
to be relatively high to detect variations in the amount of chemicals being
ischarced. ar.d t ie eby :r vide ror . czur te - sses:r e’ t f Thad-rcs c
:ie n’/i cnmer.t. y :o it: z, .impi ig -e uerc es :cr
containing insignificant amounts of toxic chemicals may be relatively low.
For monitoring the receiving environment, sampling events and frequencies
are timed to provide information during critical environmental periods.
Variables that change rapidly (e.g., water column variables) i ay be sampled
more frequently than those that change slowly (e.g., many sediment-related
variables).
Reolicat on and Comoositing Schemes
Replication (collection of multiple samples) and compositing (merging
of several samples into one) are design features that address temporal or
spatial variability in effluents nd receiving environments. Replication is
frequently used when monitoring the receiving environment to provide data
suitable for statistical analysis. The desired level of replication for
various circumstances can be determined by conducting statistical power
analyses. Composite samples are ofteri used instead of single, discrete
samples when measuring variable characteristics of discharges. The samples
can be composited over different time intervals or on the basis of flow. A
common compositing strategy is to pooi results over a 24-h period. Composi-
ting may also be used when monitoring the receiving environment for variables
that are expensive to measure and sometimes highly variable between samples
(e.g., tissue chemical concentrations in mobile organisms). In these
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instances, conipositing of several samples provides an estimate of average
conditions at a reasonable cost.
Samol inc Protocols
Sampling protocols are specified to ensure that samples are co iecceo
in a represenfative manner, properiy preserved (if necessary), and not
contaminated in the process. Meaningful laboratory results and data analyses
are dependent upon adequate sampling techniques. Standardized sampling
protocols are recommended for all 301(h) monitoring plans.
Analytical Methods
:cr tc ’ :r 1 z l methous are ecu re : . ns re :ha:
results have sufficient precision, accuracy, and sensitivity to address the
monitoring objectives. For example, if the objective is to compare the
sediment concentrations of a chemical near the outfall and at a reference
area, the precision of the method should be much greater than the expected
differences in concentration between the two areas. Standardized analytical
methods are recommended for all 301(h) monitoring plans. To ensure that
these methods are applied properly, QA/QC procedures are included in each
plan.
Data Reoorting Requirements
Data reporting requirements are specified in 301(h) monitoring plans to
ensure that all pertinent information is presented in a consistent format.
The following reporting requirements may be specified:
• Units of measurement
• Number of significant figures
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• Calculated values
- 1eans
- Standard deviations
- Various indices
• Corń parisons with permit limitations
• Results of statistical comparisons
• QA/QC information
- cplicates
- 3iar. :
• Spikes
- Calibration curves.
A schedule of data reporting is also specified in each 301(h) nionitoring
plan. Depending •on the variable, data generally are reported monthly,
quarterly, twice yearly, or annually.
21
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MONITORING PROGRAM iMPLEM NTATiON
When t e 301(h) permit becomes effective, tne monitoring program s
initiated according to the schedule specified in the permit. The monitoring
program should be implemented in a manner capable of achieving the objectives
established during the design phase (see previous chapter). The general
steps necessary to fully implement a monitoring program are outlined in
Figure 3.
Dischargers develco a qual ity assurance elan as he z:a
mp ernentir.g the ont r g r:;ram. T e :hn s ’ :e .e
sampling and analytical procedures and demonstrates the discharger’s ability
to collect data that will meet the objectives of the monitoring program.
During this initial period, the discharger determines the analytical
laboratories, personnel, equipment, and other resources needed to implement
the progtam.
SAMPLING AND REPORTING REQUIREMENTS
Samol in
The sampling schedule is determined during the design of the monitoring
program and specified in the 301(h) permit. This schedule integrates all
preservation, chain-of-custody, holding time, and analytical requirements
for the specific chemical, biological, and physical analyses. The schedule
should satisfy these requirements with minimum sampling time and human
resources. The discharger identifies appropriate laboratories to analyze all
samples and issue statements of work specifying methods (i.e., in the
permit), QA/QC requirements, and deliverables.
22
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DEVELOP
QUALITY
/ ASSURANCE PLAN
SPECIFY DETAILS
OF SAMPLING
/ AND ANALYSIS
7
r
AMPLJ J 4 —.
LABORATORY
ANALYSIS
QNQC OF ONGOING
DATA IMPLEMENTATION
4
DATA ENT 1
INTO ODES
CONDUCT DATA
ANALYSIS AND
INTERPRETATION
DISCHARGE
MONITOR?NG
REPORT
PREPARED
Figure 3. 301 (h) program implementation.
23
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Reoorti no
Monitoring results of the effluent and influent -are eoorted on
standardized discharge monitoring report forms (DMRs) that are submtted
quarterly or annually to the appropriate U.S. EPA reg onal oFfice. The
results are usually reported as maximum and average values n citner mass
(e.g., lb/day) or concentration units (e.g., nig/L) with tfte. permit limita-
tions clearly specified on the DMR. Permit violations should be addressed
in the report. All monitoring results are reported in the DMRs whenever
possible. Oischargers that extensively monitor the receiving environment
must submit those results in a separate report. Most dischargers are also
•‘ecui ed to submit an annual e ort that summarizes and interorets the
-icr.itor ng .e:ults of iat ; ar.
All data generated by the monitoring program must also be submitted to
ODES, using the procedures discussed in th next section. ODES handles a
variety of data types for marine environmental management, including permit
requirements, pollutant loadings and concentrations, and environmental
conditions in areas surrounding discharge pipes (Figure 4). Depending on
the schedule, dischargers may also use ODES to analyze their data before
submitting some of their monitoring reports to U.S. EPA.
Dischargers also submit a report assessing their overall pretreatment
program. That report should compile all related monitoring data, list
industrial dischargers, and summarize all actions taken to reduce inputs of
toxic pollutants.
ODES DATA ENTRY AND QUALITY ASSURANCE
As part of the reporting schedule, dischargers with 301(h) permits are
required to submit monitoring data to ODES and to ensure that the data have
been transferred without error or discrepancy. The ODES User’s Guide and
Data Submissions Manual assist dischargers with this task. An ODES User’s
Support Hotline has been established for questions on system access, data
24
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IN F LU E NT
V
EFFLUENT
TREATMENT PLANT
WATER QUALITY
RESOURCE/
ENVIRONMENTAL
IMP ACTS
WATER
INITIAL QUALITY
DILUTION
‘V
SPECIAL
HABITAT
SEDIMEN I S
B IOTA
WAS T EF I EL B
TRANSPORT
Figure 4. 301(h) permit monitoring: scope of ODES
-------
input, or other concerns. The procedure for submitting data to ODES s
summarized in Figure 5.
Data Entr’i
The discharger must first request permission to submit data to CDE3 y
contacting the ODES tianager in the Mar ne Operations Division. IJ.S. P
will process the request and assign a user access identification code. Iith
the user identification, the discharger will receive reference manuals that
outline access procedures and provide data file type descriptions and
formats. When entering data into ODES format, dischargers are required to
use the proper codes for biological species and chemical names. if neces-
sary, new codes can be recuested from the ODES Technical Staff.
Dischargers estaolish and adhere to quality control proceoures wnen
entering their data. These quality control procedures may include inspection
of coding forms, double entry of data, and comparison of output data to
original laboratory data sheets. Dischargers are requested to also provide
a description of the data for each ODES file type submitted, inducing
sampling and analytical techniques and QA/QC procedures.
Quality Assurance
Quality assurance review of ODES data is based on the following items:
• A description of the data set provided by the submitter and
all supporting documents needed to detail the QA/QC procedures
undertaken during sampling and analysis
• kcomputerized check of the submitted data for unacceptable or
unusual formats, codes, or ranges
• Tabular summaries of the data, in a form specific to each file
type.
26
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FCLLOW US EP OAICC PROCEDURES DURING
SAMPLE COLLECTIONAND LA8CRATORY ANALYSIS
O8T JN U S E A APDROVAL TO
SUBMIT DATA
S
-s • Subm tIer
0 Systems Operator
I - Technical Slaff
ESTA8LISN AND FOLLOW DATA ENTRY
OAIOC PROCEDURES.
PERFORM DATA EMTRY
S
S
PUT DATA INTO COES FORMAT
PREPARE DESCRIPT!CN OF DATA AND
CUALII’! CC 1ITRCL CCECURE5
SEND DATA TO ODES SYSTEMS OPERATOR
S
S
T
T
Figure 5. Procedure for submittal of ODES data.
27
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ODES QSA/QC procedures iAcorporate a two-step approach that combines computer-
ized error checks with a technical review and evaluation of the data. The
following sections describe these steps m detail
Computerized Data Screening--
The first step in the quality assurance process is a c rnpuzenzed review
of the data set. After the data are placed in temporary files, the ODES
staff screens the information using verification algorithms to ensure that
three conditions are met:
• Data are in ODES/National Oceanographic Data Center (‘ICDC)
format
• Only valid ODES/NODC codes are used
• The data ranges for numeric variables fall within pre-
determined limits.
Format checks are performed to ensure that the submitted data follow
specifications in the ODES Data Submissions manual’. All records in which
format errors are identified are flagged for subsequent inspection.
Much of the information in a data set is represented by codes. Environ-
mental variables (e.g., bottom type or sea state), equipment and techniques
used (e.g., sampling or analytical gear), and names of species or chemical
compounds are all typically represented by codes. Codes save space and,
following the creation of a dictionary of codes, allow unacceptable values
to be identified. Computer algorithms ensure that only valid ODES/NODC
codes are used ..for coded variables. If a code is not provided or if an
unrecognized code is used, the program flags the code in question and lists
all codes with flagged values.
Data fields that contain numeric variables (e.g., chemical concen-
trations) are checked to ensure that the values fall within reasonable
ranges. These range checks incorporate two levels of tests. The first
28
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level is designed to identify impossible values or gross reporting errors
(e.g.. data values several orders of magnitude above known values). For
instance, sampling time is examined to make sure that all values are 19s3
than 2 0O. Any number exceeding this value is flagged as an error. The
second level of checks is designed to highlight unusual but poss ble values.
For example, an effluent oil and grease value that exceeoed 1,000 iig,L woul ’
be flagged as an unusual value. Subsequent examination of the data 5y
technical reviewers focuses on such values to determine whether they are
simply unusual or are in error.
After the machine error checks are completed, each data set is sum-
marized in tabular formats established by the ODES technical staff.
tnformation summarized includes number and 1 ocation of all samoles. lwrcer
f o -ca: s. a ’ ‘ar’i. e epor ed. aric :c: r enc s : ‘:e’ -:a
qualifiers. Other details and summary statistics are provided For certain
file types.
A printout of the complete raw data set as submitted to ODES is also
produced. This printout, the tabular summaries, and the list of values
flagged during machine checks is sent to the technical reviewers and the
data submitter (i.e., the discharger).
Technical Data Review--
Review of the data by technical experts is the second major step of the
quality assurance process. The entire set of submitted data, the submitter’s
description of the data set, results of the computerized checks, and tabular
summaries are used to evaluate the data. Three major steps make up the
technical review process:
• Evaluation of the data set
• Resolution of problems
• Preparation of QA/QC evaluation report.
29
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As part of the data set evaluation, collection techniques (e.g., collec-
tion gear and methods, sample handling, documentation) are checked aga nst
standard or U.S. EPA-recommended procedures. The quality control measures
(e.g.. field blanks) incorporated into the sampling scheme are assessed.
The evaluation of analytical methods examines topics such as ecui ment.
calibration, and QA/QC checks, and their effect upon the interpretation •of a
data set. Examination of the actual data values has the dual goals o
resolving any format or code errors revealed by the_computerized screening
and establishing that the data set contains reasonable values for the
variables measured. The several steps in this process each involve exami-
nation of the computerized format checks, comouterized range checks, and
actual data values.
• , ?‘ * .‘_ , -
•..• . .g ... .
Problems that cannot be corrected by the reviewers are discussed with the
data submitter. Upon notification by the reviewers, the ODES staff ensures
that the data, while still in temporary computer files, are corrected based
on the discharger’s instructions. For major errors that cannot be easily
corrected by changes to the existing temporary files, submittal of a revised
data set may be requested. In this case, the computerized screening and
technical review will be performed again with the revised data.
The data submitter is asked to certify the data set when the data are
submitted. Concurrent with the technical review, the data submitter also
reviews the data and provides the ODES staff with corrections.
For each data set reviewed, the technical staff produces a report
emphasizing the major features of the data set that affect its use and
interpretation by ODES users. The report includes a brief description of
the data set, including location of the study, locations of sampling
stations, and type and number of samples collected. Major issues identified
by either the submitter or the technical reviewer that affect the use of the
data are also described. Unresolvable problems are also fully described,
emphasizing the severity and scope of the problem (i.e., how severely the
data are affected and whaT proportion of the data set is affected).
30
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An abstract of th& report suitable for entry into the ODES system for
on-line viewing is also produced. The abstract prese”ts a descrlDtlon of
the data and synopsis of the QA,’QC evaluation for each data see.
ODES DATA ANALYSIS
ODES off rs users a wide range of easy-to-usa data anaiysis procedures
or “tools,” and enables users to retrieve and analyze any combination of
monitoring data in the database. The types of data available in ODES are
summarized in Figure 6. The tools (listed in Table 3) enable users to
perform statistical tests, summarize results, and produce reports and
graphics. A supplement to the ODES User’s Guide describes and gives
examples of the use of all the ODES tools. Data analysis procedures
aoolicaole to d’fferent : es ci on:or’nc a : i - . -
chapter, called “Monitoring Program Evaluation.”
31
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ODES DATABASE
MONITORING DATA
• E fIuent ata
• Water Quality Data
• Benthic Survey Data
• Fish Histopathology Data
• Bloaccumulation Data
• Trawl/Seine Sampling Data
• Bioassay Data
• BactenaVViral Data
• Sediment Poi utant Data
• Sediment Grain Size
AnaIys s Data
PROGRAM DATA
• ac:iities Data
Name
Location
Processes
Receiving Water Body
• Permit/Application Data
Permit Number
Application Date
U.S. EPA Region
• Monitoring Plan Data
Data Types
Frequency of Collection
Permit Limits
• Criteria and Standards Data
State
Federal
Figure 6. ODES data types.
32
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TABLE 3. ODES ANALYTftAL AND DECISION—SUPPORT TOOLS
Tool
Number Tool Description
1 Plot of one variable over time
2 Plot of éveral variables over time (overlay)
3 Plot of means over time (with standard error bars)
4 Univariate means
5 Bar charts
S \Iertical profiles
r— esz or - oi cateo caca
ii WilcoxoniMann— hitney U test for repl catea aaEa
12 One—way analysis of variance for replicated data
13 Kruskal—Wallis K—sample location test for replicated data
14 Statistical power analysis
X—Y scatterplot with correlation statistics
21 Regression of a variable over time
30 Cluster analysis
52 Calculation of an LC 50 value for bioassay data
60 Plume models
61 DECAL (particulate deposition model)
70 National maps
71 Sectional maps
72 Study area maps
90 Mass loading
91 Nearfield pollutant loading
92 Water quality standards
110 Retrieval of benthic survey data
111 Retrieval of auxiliary variables for benthic data
120 Retrieval of bioaccumulation data
121 Retrieval of auxiliary variables for bloaccumulation data
33
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TABLE 3. (Continued)
130 Retrieval
140 Retrieval
141 Retrieval
150 Retr eval
151 Retrieval
160 Retrieval
161 Retrieval
170 Retrieval
171 Retrieval
180 Retrieval
181 Retrieval
etr e’iai
191 Retrieval
275
300
0 1
302
of fish pathology cata
of effluent data
of auxiliary variables for effluent data
of receiving water cuality data
of auxiliary variables for water quai ty data
of grain size data
of auxiliary variables for grain size data
of sediment pollutant data
of auxiliary variables for sediment pollutant data
of trawl/seine data
of auxiliary variables for trawl/seine data
c ‘ as3ay cat
of auxiliary var ables for b’oassay data
Benthic indices
Summary of permits and monitoring-plans
301(h) facilities summary
301(h) benthic survey data summary
34
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MONITORING DATA EV LUATICNS
The data collected as part of 301(h) monitoring programs are sub:ec ed
to various kinds of analyses to evaluate program oojectives. onitoring
program evaluations are conducted at three primary levels of detail
(Figure 7). The most detailed and comprehensive analyses are conducted
prirrarily by U.S. EPA regions, with support from ORD, to determine permit and
regulatory compliance. The regions and ORD also conduct analyses of
monitoring program effectiveness. These analyses are used to determine
whether chances ieeded i t e esicn nd s c ations of
:3r g :rograms. t —.e ‘ hes: eve . ..s
conduct overall evaluations of all 301(h) monitoring programs to determine
program accomplishments and regional or national trends in impacts of sewage
discharges.
REGULATORY AND PERMIT COMPLIANCE
Permit compliance is evaluated to determine whether all the data
specified in the monitoring plan were collected, and whether all permit
conditions, including reporting requirements, were followed. The degree to
which the sampling and analytical protocols effectively documented any
changes in the receiving environment is also reviewed as part of the
compliance evaluation. ODES data analysis tools can be used to determine
compliance with these qualitative permit conditions. First, data retrieval
tools are used to verify that dischargers have collected the correct
samples, performed the a propriate analyses, and submitted the data to U.S.
EPA for review. ODES also stores both text and tables describing the
monitoring plans and permit * limits for all approved 301(h) dischargers.
ODES Tool Number 300 provides access to this information. From the output
of this tool, users can identify the variables that should be measured,
sampling frequency, and effluent limits.
35
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(A)
0•s
—4
-- -4
OVERALL
301(h) PROGRAM
EVALUATION
PERMIT
RENEWAL
MONITORING
DATA
REGULA1 ORY
PERMIT
COMPLIANCE
MONITORING
PROGRAM
EFFECTIVENESS
Figure 7.
301(h) monitoring data evaluation.
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The compliance evaluation also includes determination of ihether
concentrations of both toxic and conventional pollutants in the influent.
effluent, and receiving iater exceeded maximum (or mlnlnum) quant: : e
permit limits and applicable water quality criteria. For auantitati/e.
limits, ODES tools can be used to compare the concentration of a toxic
pollutant in the effluent or influent with thE concentration li;nit specfied
in the permit. For example, Tool Number 2 a iows the user to piot several
variables over any time frame specified. A plot could be generatea s cwing
concentrations of PCBs, total suspended solids, and lead for all composite
effluent samples taken in 1985. Asunimary report of the permit limits for
these variables could be generated and the number of permit violations for
1985 determined From the graph. Tool Number 4 for univariate statistics can
be used to calculate monthly, cuarterly. and yearly averages. Tool ‘ ber
O is usea to ca’cJ:at -iass aoinas. These :oos re jse: : :: :i ’e -
monitoring data to the permit limits with the appropriate reporting u.iit.
Data analysis tools are also used to test hypotheses and assumptions
related to the objectives of the programs and to determine whether the dis-
charger has met the requirements for the biological, water quality, and
effluent monitoring programs specified in 40 CFR 125.62. In general, the
monitoring data are evaluated to determine whether the discharge of less-
than-secondary treated wastewater decreased the ambient water quality or
impacted marine biota. Representative questions addressing the evaluation
of environmental effects of the discharge include the following:
• Did comparisons of biological communities at different
sampling stations indicate adverse effects near the outfall?
• Did Investigations indicate accumulation of toxic pollutants
-in the sediments or associated toxic impacts to the marine
biota near the outfall?
• Did the discharge potentially harm human health by degrading
nearshore water quality in recreational areas or by causing
the accumulation of toxic pollutants in commercial and
recreational fishes?
37
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Th-e first question concerning biological impacts involves an evaluation
of many biological variables and recognizes the natural variability of those
measurements. As discussed previously, statistical analyses can be usea to
evaluate the hypotheses formed for each variable. ODES Tool 12 for analysis
of variance is particularly important in assessing interstation differences
in biological variables.
One hypothesis related to the second question involves the determination
of whether the concentration of particular chemical or group of chemicals in
the sediment varies with distance from the outfall. ODES Tool Number 4 can
be used to plot bar charts of chemical concentrations at stations within the
ZID, at the ZID boundary, and outside the ZID to show whether the concen-
trations tended to increase or decrease with distance from the outfall. Tool
Number ZO can :e used to cDrreThte the edi ient :oiij:an: ca:a Mt
benthic survey data. If sediment concentrations inversely correlate with
total abundance of benthic invertebrates and the previous plot indicates
higher concentrations near the outfall, then the discharge could be causing
an adverse impact on the biological community from the accumulation of toxic
pollutants in the sediments.
Long- or short-term changes ‘in the characteristics of influent and
effluent are also important for assessing the performance of the wastewater
treatment plant and the effectiveness of the toxics pretreatment program.
Both visual and statistical evaluation of changes in the influent and
effluent can be made using ODES. Tools Number i and Number 2 can plot all
measurements of a variable made within a given range of dates. Tool
Number 21 can fit a regression line to such a data set. It can also
calculate and display the confidence limits for the regression line to
evaluate whether there is an increasing or decreasing trend in the measure-
ments.
EFFECTIVENESS OF 301(h) MONITORING PROGRAMS
To be effective, 301(h) monitoring programs should document changes in
.aJ.l important chemical, biological, and physical variables related to the
effects of the discharge on the receiving environment, while ensuring that
38
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all sampling and analysis procedures are conducted efficiently. An important
part of 301(h) rncnitoring program evaluations concerns a continuina assess-
ment of whether the existing programs represent an efficient aria pr cent
approach to meeting the program objectives. These evaluations are con ucted
to ensure that individual monitoring prog ams yield information of sufficient
quality to assess impacts of the discnarge, without any waste of resources
by the permittee.
Evaluations of monitoring program effectiveness are initiated once
sufficient data have been collected (usually 1-2 years) to provide meaningful
analyses of variability and general trends. The most intensive evaluations
are conducted prior to permit reissuance. At this time, the entire program
is evaluated for any needed chances in design. T he advantace f edes cr rc
: e r cram is : az 5 jears ionit:r’ a a:a car :e ‘_ ac .o :rea— - -
program and indicate the most appropriate sampling and analysis procedures
for determining the effects of the discharge. The following are repre-
sentative questions that are addressed when determining how effectively a
monitoring program has met its objectives:
• Did the influent and effluent monitoring show temporal trends
in the concentration of toxic pollutants indicating that
source control has been effective and potential toxicity to
marine biota has been reduced?
• Did the station locations allow analysis of the spatial extent of
the discharge effects?
• Were all chemical, biological, and physical variables
necessary for evaluating the effects of the discharge?
• Was the number of replicate samples collected sufficient to
adequately assess testable hypotheses?
The analyses needed to answer these kinds of questions and to conduct a step-
by-step evaluation of all monitoring program components will be presented in
39
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an upcoming guidance document entitled, “Guidance for Evaluating the.. Effec-
tiveness of 301(h) Monitoring Pr grams .
OVERALL 301(I’r) PROGRAM EVAL!JATIONS
Collective data from all 301(h) monitoring programs are re’newec to
evaluate the statüs of the 301(h) program from a national perspective. The
following kinds of analysis may be undertaken:
• Identification of large-scale environmental impacts and trends
• Comparison of individual monitoring programs to identify tr e
most effective orogram designs
• Decision-making support concerning permit issuance or renewa
• Documentation of overall program accomplishments.
The monitoring data can also be used to assess the effectiveness of indi-
vidual toxics control programs and to evaluate whether toxics control is as
effective as secondary treatment for reducing impacts on the environment.
As a comprehensive database for all 301(h) permit dischargers, ODES is
used to evaluate overall trends in a region and to make comparisons between
different monitoring programs. For example, Tool Number 5 will produce a
bar chart showing, for each discharger within the region, the mean sediment
concentration of a toxic pollutant from all stations. Tool Number 12, one-
way analysis of variance, will enable the stations within a particular study
area to be grouped and compared to stations from another study area in an
effort to determine whether there are significant differences in conditions
between the two study areas.
PROGRAM MODIFICATIONS
As discussed previously, 301(h) monitoring programs are subiect to
modification based on results of the data analyses. The objective of any
40
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mod fication is to make the monitoring program more efficient in meeting the
defined objectives. If the results indicate that a particular component is
not supplying interpretable data, the component may be el rninateo to reduce
an unnecessary expenditure of resources by the permittee. Alternatively, if
the results suggest an impact for a variable but the sainDl ing intensity- is
insufficient to adequately define the impact, the monitoring program ay be
increased.
In general, monitoring programs and 301(h) permits are modified only
when the discharger applies for permit renewal. In some cases, modifications
may be necessary during the term of the permit. Minor modifications
generally are nonsubstantial in nature (e.g., corrections of typographical
errors) or establish more stringent permit conditions. Major modifications
are substar.tial i rat r •)r sza lisn less zr ncent concit’ s :-
procedural standpoint, the two kinds of modification are different because
major modifications require public notice, whereas minor modifications
do not.
Modifications to the monitoring program are influenced by whether or not
environmental impacts are found (Figure 8). Environmental impacts may be
attri’butable to a single monitoring variable (e.g., bioaccumulation of PCBs
in fish, when PCBs are found in discharge but not elsewhere in the area) or
to the overall effect of the discharge (e.g., decreased abundance in the
benthic macroinvertebrate population near the outfall). If the environmental
impacts can be attributed to the discharge, the application for 301(h)
permit renewal should be evaluated to determine whether these impacts can be
reduced in the future. The monitoring program should be redesigned to focus
on the environmental impacts by addressing the following objectives:
• Determine the magnitude and extent of the environmental effect
• Determine the toxic or conventional pollutants causing the
effect
• Document changes in pollutant concentrations in the discharge
and environment with increased accuracy and precision.
41
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Figure 8. 301(h) monitoring program review.
-------
The first objective may be addressed by increasing the scope of the moni-
toring program. For example. if substantial bioaccumulation was found in
fishes near an outfall. assessments of histopatholcgy or reproductive
success might be included in the revised monitoring. program to evaiuat
potential toxic impacts on the fishes. The latter two objectives may be met
by increasing the sampling frequency of toxic pollutants i the nfi ent.
effluent, and receiving environment.
If environmental impacts were not found for a variable during . the
initial term of the permit, at least two kinds of modification to the re’iised
monitoring program could be made. If the absence of an impact could have
resulted from an inadequate study design. the variable could continue to be
monitored under more aoorooriate study desian. However, if the or’ci ai
sz..dy es ;n cec at r.d the abs r.ce of i: c:
valid, the variable may be deleted from the revised monitoring orogram.
Modifications can also be based on compliance-with quantitative permit
limitations related to the characteristics of the discharge or the operation
of the treatment plant. Examples of possible compliance-based modifications
toa 301(h) monitoring program include the following:
• Addition of sampling locations upstream from a treatment
plant to better evaluate pretreatment processes
• Specification of new sampling or analytical protocols to
increase the accuracy or precision of measurements
• Increase in the sampling frequency for pollutants found to be
highly variable or io -high concentrations in the discharge or
receiving environment
• Deletion of pollutants that are expensive to measure and that
never violate permit limits.
Modifications can also be based on external factors related directly to
events that have occurred subsequent to issuance of the 301(h) permit.
43
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External factors that affect the monitoring program when the perrrnt is up
for renewal include changes in regulations and aopiicable federal. state.
and local criteria; beneficial and recreational uses of the r eceIv1ng
environment; and P01W operation. Flow, equipment. or industrial inputs.
Exaniples of modifications resulting from changes in xternal Factors include
the following:
• Decrease in a permit limit because a new water quality
criterion was established
o Decrease in the frequency of nearshore monitoring because a
recreational beach downstream from the outfall was closed.
1any f t e ian e i ana F c:c’ that ;c: r : ..r-- c
30 1(h) permit are reported to U.S. EPA through the annual monitoring reports
prepared by individual di.schargers. Changes in factors within the P01W that
will dramatically alter the original assumptions of the monitoring program
should be extensively evaluated if these changes are to be made during the
term of the existing 301(h) permit.
44
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