September 30, 1999
EPA-SAB-EEC-99-019
Honorable Carol M. Browner
Administrator
U.S. Environmental Protection Agency
401 M Street SW
Washington, DC 20460
Subject: Review of 1996 Risk Management Plan for Wet Weather
Flows and the 1997 Urban Infrastructure Research Plan.
Dear Ms. Browner:
The Wet Weather Flows and Urban Infrastructure Subcommittee of the Science
Advisory Board's Environmental Engineering Committee met on February 25-26, 1999
to review 1996 Risk Management Plan for Wet Weather Flows and the 1997 Urban
Infrastructure Research Plan in a public meeting in Washington, DC. In addition to the
technical review of both plans, the Subcommittee considered the overall direction,
quality, and coordination of the plans and associated research program and also
evaluated coordination with the Office of Water and external research organizations.
The Subcommittee commends the Office of Research and Development and the
Office of Water, for developing research plans on wet weather flows. The issue is
important because wet weather flows continue to threaten water quality, aquatic life and
human health. It is the unanimous view of the Subcommittee that implementing the
research plans will generate information critical to improving US water quality. The
decision to focus a substantial part of its efforts on investigating methods to reduce
stressors such as pathogenic contamination is particularly well-considered because
such contamination is the greatest water quality threat to US public health. The
Subcommittee also compliments the Office of Research and Development for
highlighting key infrastructure issues presently facing the US in the area of water
supply and water quality protection.
The Subcommittee's detailed comments appear in the attached report. We
would like to highlight several of our recommendations here.
a) Risk managers find it easier to understand and apply research findings
when the results of individual projects are clearly integrated into a well-
defined framework that assists decision makers. Such decisions
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inevitably involve trade-offs between risk reduction and costs. The 1996
Risk Management Plan for Wet Weather Flows lacks overarching
guidance on how the results from projects are to be used to support the
EPA Risk Management Paradigm. Thus, one of the Subcommittee's
major recommendations is that ORD develop a plan to ensure that risk
reduction and costs are fully addressed within the context of wet weather
flow research activities.
The Office of Research and Development should fully address
costs and risk reduction in its wet weather flows research activities; this is
our most important recommendation.
b) In order to provide a complete basis for regulatory action and decision
making, the Agency should extend its present research effort into a
variety of additional areas (e.g., differentiation between chemical and
biological loadings, real-time data acquisition on WWF quality and
quantity, temporal and spatial scaling issues, the role of colloids in WWF,
automated control technologies, and WWF in coastal areas). A
fundamental approach to research within the context of WWF
applications should be undertaken such that the results of the work are
broadly extensible.
c) In order to apply its limited resources in a cost-effective manner, ORD
should develop a transparent methodology, based on the risk
management paradigm, to prioritize its programs and projects.
d) In developing research programs and projects on wet weather flows, the
Office of Research and Development, with the Office of Water, should
implement the Agency's data quality objective process both earlier and
more broadly. The data quality objective process and that incorporates
an appropriately broad group of stakeholders will ensure that the relevant
issues are identified and can be addressed. The process also conserves
resources by ensuring that the data collection activities will be precisely
those required to address the water quality decisions that must be made.
Subsequently, a prioritization mechanism to ensure the most immediate
and effective results should be implemented.
The Subcommittee encourages the Office of Research and Development and the
Office of Water to continue coordinating their efforts and to build upon the success they
have already enjoyed by gathering data on costs and risk reduction; implementing
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the data quality objective process with stakeholder involvement; and considering
watershed-specific applications. The Subcommittee looks forward to your written
response to its report.
Sincerely,
/signed/
Dr. Joan Daisey, Chair
Science Advisory Board
/signed/
Dr. Hilary Inyang, Chair
Environmental Engineering Committee
Science Advisory Board
/signed/
Dr. Domenico Grasso, Chair
Wet Weather Flows and Urban
Infrastructure Subcommittee
Environmental Engineering Committee
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NOTICE
This report has been written as part of the activities of the Science Advisory
Board, a public advisory group providing extramural scientific information and advice to
the Administrator and other officials of the Environmental Protection Agency. The
Board is structured to provide balanced, expert assessment of scientific matters related
to problems facing the Agency. This report has not been reviewed for approval by the
Agency and, hence, the contents of this report do not necessarily represent the views
and policies of the Environmental Protection Agency, nor of other agencies in the
Executive Branch of the Federal government, nor does mention of trade names or
commercial products constitute a recommendation for use.
Distribution and Availability: This Science Advisory Board report is provided to the
EPA Administrator, senior Agency management, appropriate program staff, interested
members of the public, and is posted on the SAB website (www.epa.gov/sab).
Information on its availability is also provided in the SAB's monthly newsletter
(Happenings at the Science Advisory Board). Additional copies and further information
are available from the SAB Staff.
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ABSTRACT
The Wet Weather Flows and Urban Infrastructure Subcommittee of the EPA
Science Advisory Board's (SAB) Environmental Engineering Committee reviewed the
Office of Research and Development's 1996 Risk Management Plan for Wet Weather
Flows and the 1997 Urban Infrastructure Research Plan. Wet weather flows are one of
the largest remaining threats to water quality, aquatic life and human health and the
Subcommittee commends EPA for its initiative in developing these two research plans.
The Subcommittee's most important recommendation is that EPA fully address
both risk reduction and costs within its wet weather flows research activities.
The five research areas identified in the 1996 Risk Management Plan for Wet
Weather Flows are appropriate. However, the corresponding research efforts are too
narrow and must be couched in the context of risk reduction. The Subcommittee
makes specific suggestions for broadening the research program to improve the basis
for risk management decisions. The 1997 Urban Infrastructure Plan - Water and
Wastewater Issues identified appropriate areas and addressed them in a thoughtful
manner.
Keywords: wet weather flows, infrastructure, watershed management
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U.S. ENVIRONMENTAL PROTECTION AGENCY
Science Advisory Board
Environmental Engineering Committee (FY99)
CHAIR
Dr. Hilary I. Inyang, Director, Center for Environmental Engineering and
Science Technologies (CEEST), University of Massachusetts, Lowell,
MA
MEMBERS
Dr. Edgar Berkey, Vice President and Chief Science Officer, Concurrent Technologies
Corporation, Pittsburgh, PA
Dr. Calvin C. Chien, Senior Environmental Fellow, E. I. DuPont Company,
Wilmington, DE
Mr. Terry Foecke, President, Waste Reduction Institute, St. Paul, MN
Dr. Nina Bergan French, President, SKY+, Oakland, CA
Dr. Domenico Grasso, Professor &Head of Department in Civil and Environmental
Engineering, University of Connecticut, Storrs, CT
Dr. JoAnn Slama Lighty, Associate Dean for Academic Affairs and Professor of
Chemical Engineering, University of Utah, Salt Lake City, UT
Dr. John P. Maney, President, Environmental Measurements Assessment, Hamilton,
MA
Dr. Michael J. McFarland, Associate Professor, Utah State University, River Heights,
UT
Ms. Lynne M. Preslo, Senior Vice President for Technical Programs, Earth Tech,
Long Beach, CA
Science Advisory Board Staff
Mrs. Kathleen W. Conway, Designated Federal Officer, Science Advisory Board
(1400A), U.S. Environmental Protection Agency, 401 M Street S.W., Washington, DC
Mrs. Mary L. Winston, Management Assistant, Science Advisory Board (1400A)
U.S. Environmental Protection Agency, 401 M Street S.W., Washington, DC
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Science Advisory Board
Environmental Engineering Committee
Wet Weather Flows and Urban Infrastructure Subcommittee
Chair
Dr. Domenico Grasso, University of Connecticut, Storrs, CT
Members of SAB Committees:
Dr. Kenneth W. Cummins (EPEC), Tarpon Bay Environmental Lab, Sanibel, FL
Dr. Michael J. McFarland (EEC), Utah State University, River Heights, UT
Dr. Lee D. (L.D.) McMullen (DWC), Des Moines Waterworks, Des Moines, IA
Consultants:
Dr. Byung Kim P.E., Ford Motor Company, Dearborn, Ml
Dr. Charles Noss. Water Environment Research Foundation, Alexandria, VA
Dr. Thomas Theis, Clarkson University, Potsdam, NY
Dr. Mark R. Wiesner, Rice University, Houston, TX
Science Advisory Board Staff
Kathleen White Conway, Designated Federal Officer, Science Advisory Board
(1400A), U.S. Environmental Protection Agency, 401 M Street S.W.,
Washington, DC
Mary L. Winston, Management Assistant, Science Advisory Board (1400A)
U.S. EPA, 401 M Street SW, Washington, DC
IV
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TABLE OF CONTENTS
1. EXECUTIVE SUMMARY 1
2. INTRODUCTION 4
3. DIRECTIONS, QUALITY, AND COORDINATION 5
3.1 Findings 6
3.1.1 Research Quality 6
3.1.2 Research Direction 7
3.1.3 Research Coordination 9
3.1.4 Summary and Recommendations 10
4. REVIEW OF THE 7996 RISK MANAGEMENT RESEARCH PLAN
FOR WET WEATHER FLOWS AND THE URBAN INFRASTRUCTURE
PLAN - WATER AND WASTEWATER ISSUES 11
4.1 Findings and Recommendations: 1996 Risk Management Research
Plan for Wet Weather Flows 11
4.1.1 Research Objectives and Questions 11
4.2 Findings and Recommendations: 1997 Urban Infrastructure Research
Plan - Water and Wastewater Issues 14
4.2.1 General Findings and State-of-the-Science Write-Ups 14
4.2.2 Research Objectives and Questions 15
4.3 Summary and Recommendations 17
5. OFFICE OF WATER NEEDS 19
5.1 Findings 20
5.2 Recommendations 22
APPENDIX A: Expanded Charge for the Review A-1
APPENDIX B: Documents Reviewed B-1
APPENDIX C: Wet Weather Flows and Urban Infrastructure Research Plan
Review Team Assignments C-1
APPENDIX D: Summary of Research Programs and Projects that Specifically
Address Office of Water Technical Research Needs D-1
REFERENCES R-1
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1. EXECUTIVE SUMMARY
At the request of the Office of Research and Development (ORD), a specialized
Subcommittee of the Science Advisory Board's (SAB) Environmental Engineering
Committee reviewed the Agency's wet weather flow and urban infrastructure research
plans. These documents are the 1996 Risk Management Plan for Wet Weather Flows
and the 1997 Urban Infrastructure Research Plan.
In fulfilling its charge, the Subcommittee considered the overall direction, quality,
and coordination of the research plans and program; conducted technical reviews of
the two research plans; and considered coordination with EPA's Office of Water and
with external research organizations. Appendix A contains the full text of the
negotiated charge and Appendix B lists the documents reviewed.
The Subcommittee's major findings and recommendations follow.
a) Wet weather flows are one of the largest remaining threats to water
quality, aquatic life and human health. The Subcommittee therefore
commends NRMRL personnel for their efforts to address the complex
problems associated with wet weather flows and for their initiative in
developing these two research plans.
b) The 1996 Risk Management Plan for Wet Weather Flows has a critical
lack of overarching guidance on how the results from projects are to be
used to support the EPA Risk Management Paradigm. Thus, the most
important recommendation of this review is that a plan be developed to
ensure that risk reduction and costs are fully addressed within the context
of wet weather flows research activities.
c) The 1996 Risk Management Plan for Wet Weather Flows identified five
research areas to address various aspects of WWF issues:
1) characterization and problem assessment;
2) watershed management;
3) toxic substance impacts and control;
4) control technologies; and
5) infrastructure improvement.
These five areas are sufficiently broad to cover current and
anticipated concerns and as such are appropriate.
d) Pathogenic contamination associated with WWF poses a significant
threat to public health. The Agency has properly identified this as a major
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area of research. However, additional research thrusts are required to
provide a complete basis for regulatory action and better decision making
or to develop appropriate technologies for monitoring and control. The
Subcommittee therefore suggests the Agency consider more fundamental
research initiatives that underpin the application of wet weather flow
mitigation in the following areas:
1) differentiation between total loadings of chemical and biological
contaminants and their impacts as a basis for setting standards
and evaluating improvement;
2) improvements in our ability to obtain real-time information on WWF
quality and quantity such as the development of pathogen-specific
sensors;
3) the temporal and spatial scaling of physical, chemical and
biological processes in wet weather flows and urban watersheds
and the interactions with neighborhood, city, county and state
institutions;
4) fundamental aspects of colloidal transport, origin, and composition,
including a better understanding of the properties of cohesive
sediments;
5) focused research on control technologies that can easily be
brought on-line during storm events without operator intervention;
and
6) impacts of wet weather flows in depressing salinities in coastal
estuaries.
e) The 1997 Urban Infrastructure Plan - Water and Wastewater Issues
identified and addressed major areas in a thoughtful manner. To
strengthen this research plan and sharpen its focus, the Subcommittee
recommends that:
1) the purpose and aim(s) of research be clearly defined and linked to
research needs on both capacity and integrity issues of
infrastructure systems (this will also help prioritize research
needs); and,
2) engineering and science issues on infrastructure systems, with
regard to sustainable technology development, be clearly identified
before developing detailed research needs.
Additional research areas that should also be considered include:
1) infrastructure systems for greenfield sites; and
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2) impacts of seasonal and regional differences on infrastructure
systems and natural and man-made disasters on infrastructure
systems, industry specific infrastructure issues, and impacts of
natural and man-made disasters.
f) To enhance the value of its research programs to Agency needs, the
Subcommittee encourages NRMRL to develop a more formal process
through which research programs and projects that address the technical
research needs of individual program offices may be identified, e.g.,
balancing Office of Water technical research needs, which include a
strong programmatic focus on nonpoint source pollution issues, with
ORD's present emphasis on point source pollution control. In order to
apply its limited resources in a cost-effective manner, ORD should
develop a transparent methodology, based on the risk management
paradigm, to prioritize its programs and projects.
g) ORD should employ the data quality objective process earlier and more
broadly in program and project development. The data quality objective
process is not for the scientists only; it is a useful way to engage decision-
makers in research planning. Implementing the process early and
broadly ensures that the interest of all relevant stakeholders are
addressed. The process also conserves resources by ensuring that the
data collection activities will be precisely those required to address water
quality decisions.
h) Although the Office of Water and the multi-agency 1998 Clean Water
Action Plan recognize the unique water issues associated with tribal
lands, neither research plan addresses tribal issues. The Subcommittee
encourages ORD to develop water related research programs that are
broad based and whose results would be applicable to tribal lands as well
as other areas of the United States. In some instances, water quality
issues associated with tribal lands are substantially different from those
facing other parts of the US. These differences are particularly apparent
when addressing the issues of total maximum daily loads (TMDLs) and
drinking water system management. Therefore, substantial research
efforts directed specifically at addressing water issues involving Native
American communities should be added.
i) Finally, the rural (agricultural), urban, and environmental components of
risk from wet weather flows need to be systematically addressed at the
watershed level. Establishing surface/ground water interactions is a
prerequisite for understanding these relationships and developing
protocols for retention and processing of wet weather flows.
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2. INTRODUCTION
Wet weather flows remain one of the largest threats to water quality, aquatic life,
and human health. The Office of Water's National Water Program Agenda for 1998-9
relates many of the serious water pollution problems remaining throughout the country
directly to polluted runoff. Similarly, ORD's 1996 Risk Management Plan for Wet
Weather Flows recognizes the seriousness of wet weather flows and addresses three
types of untreated urban discharges that occur during storms: combined sewer
overflows, stormwater sewer overflows, and sanitary sewer overflows.
The Office of Research and Development's (ORD) National Risk Management
Research Laboratory (NRMRL) plans and conducts research on the risk management
aspects of urban wet weather flows. This work is largely conducted by NRMRL's Water
Supply and Water Resources Division, especially the Urban Watershed Management
Branch. ORD requested SAB review of the 1996 Risk Management Plan for Wet
Weather Flows. After an introductory briefing to the Environmental Engineering
Committee on December 1, an expanded charge was negotiated that included review of
the 1997 Urban Infrastructure Research Plan.
In fulfilling its charge, the Subcommittee considered the overall direction,
quality, and coordination of the research plans and program; conducted technical
reviews of the two research plans; and considered coordination with EPA's Office of
Water and with external research organizations, including the Water Environment
Research Foundation and the American Society of Civil Engineers. Appendix A
contains the full text of the negotiated charge and Appendix B lists the documents
reviewed.
The documents listed in Appendix B were submitted to the Subcommittee at or
prior to the review meeting on 25-26 February 1999 at EPA Headquarters in
Washington, DC. In preparation for the February meeting, two telephone conference
call were held. On the January 15, 1999 conference call, the chair divided the
Subcommittee into three working groups (see Appendix C) to address various aspects
of the charge. The February 9, 1999 conference call was a publicly announced FACA
meeting where additional fact finding was pursued and initial findings discussed. This
report presents the consensus comments in response to the charge given to the
Subcommittee.
The body of this report is comprised of three sections: a) Directions, Quality,
Coordination; b) Review of 1996 Risk Management Plan for Wet Weather Flow and the
1997 Urban Infrastructure Research Plan - Water and Wastewater Issues; and c)
Office of Water Needs and Coordination. Each section presents the findings of
the Subcommittee and associated recommendations.
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3. DIRECTIONS, QUALITY, AND COORDINATION
The ORD asked that the Subcommittee assess the direction, quality and
coordination of research being planned and implemented.
ORD's plans are described in the 1996 Risk Management Plan for Wet Weather
Flows and the 1997 Urban Infrastructure Research Plan - Water and Wastewater
Issues. Research implemented and research completed were described in additional
documents provided by ORD, listed in Appendix B. In considering internal coordination
issues, the reviewers relied on the Office of Water's "National Water Program Agenda-
1998-1999", interactions with Office of Water staff at public meeting, and the familiarity
of some reviewers with the Clean Water Action Plan. In considering coordination with
outside research organizations, the reviewers relied on their own experience regarding
research funded by the National Science Foundation, the American Society of Civil
Engineers, and the Water Environment Research Foundation. Water Environment
Research Foundation staff also provided a written summary of twenty-three projects
completed, on-going, and initiating along with a description for each of the projects.
The 1996 Risk Management Plan for Wet Weather Flows is a balanced research
plan, taking a reasonable approach on many important issues. The overall goal of
reducing risk from wet weather flows, as stated in 1996 Risk Management Plan for Wet
Weather Flows, is to protect human health and the environment. While the research
plan focuses on the risk management portion of the risk assessment/risk management
paradigm, it included elements of risk characterization, dose-response and exposure.
The research plan addresses five logical and well-chosen areas. These are:
a) characterization and problem assessment,
b) watershed management,
c) toxic substance impacts and control,
d) control technologies, and
e) infrastructure improvement.
The individual projects represent the Agency's best thinking on research needs
while attempting to balance the pragmatic problem of allocating sufficient resources.
Resource constraints are relieved somewhat by leveraging research money with funds
from other agencies and municipalities.
Portions of the research plan could be better defined. A better definition of the
program's destination and a road map outlining how to "get there", would allow the
reader both to better understand what this research program intends to achieve and to
measure progress along the way. Research needs currently focus on urban wet
weather flows issues leaving the many suburban, rural and agricultural wet weather
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flows problems unaddressed. The characterization & problem assessment area and
the watershed management area can be strengthened.
The research plan is largely implemented by ORD's Urban Watershed
Management Branch. The Branch describes its mission as ". . . to research, develop
and demonstrate technologies, systems and methods required to manage the risks to
public health, property and the environment from Wet Weather Flows. We provide
high quality data and information to our clients in appropriate formats." Research
program documents included state-of-the-science reviews, a list of research questions,
a list of research needs for each question, and a list of in house and extramural
projects.
The research program is intended to meet the following eight Branch objectives:
a) Develop and deliver high quality products and support to clients.
b) Implement the 1996 Risk Management Plan for Wet Weather Flows and
the 1997 Urban Infrastructure Research Plan."
c) Present and publish results as much as possible as sole or primary
authors in peer reviewed journals.
d) On a voluntary basis, establish individual development plans.
e) Improve branch facilities for conducting research.
f) Maintain and expand ties with universities.
g) Enhance communication with other NRMRL locations and other external
contacts electronically.
h) Improve use of diminishing extramural resources.
These eight Branch objectives constitute the core of the research program. The
objectives and the associated activities are consistent with the list of projects. The
work of the branch connects to the research plans and, thereby, to EPA's watershed
and risk management goals. The Subcommittee would like to see the connection with
the overarching EPA watershed and risk management goals made more transparent.
This is especially important because the plan for meeting these objectives (prioritized
and revised) is critical to the success of the ORD's Urban Watershed Management
Branch program.
3.1 Findings
3.1.1 Research Quality
The Subcommittee commends the research staff of EPA for publishing on the
topic of wet weather flow over the years. In FY98 the research staff published more
than a dozen papers relevant to wet weather flows and urban infrastructure; these
papers appeared in peer reviewed journals and peer reviewed conference proceedings.
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The journals include Water Resources Planning and Management of the American
Society of Civil Engineers, Environmental Science and Technology, and Journal of the
American Water Works Association. Other years are similar in terms of productivity
and journal quality. Branch staff have also summarized the literature on wet weather
flow for the annual Water Environment Federation Literature Review. The staff has
published their research plan in Water Resources Planning and Management, ASCE
May/June 1998.
Because the publications have appeared in peer reviewed journals, the
Subcommittee is satisfied that the articles and citations provided indicate that research
completed thus far has been of acceptable quality, applying the following standard:
As performed by the technical community, peer review is the expert
scrutiny of a technical report by professionals in the same field of
expertise for independent confirmation that (1) the report is presented in a
technically sound, understandable and internally consistent manner; (2)
the observations made were obtained by methods approved by the
particular scientific discipline; and (3) the communication as a whole is a
worthwhile contribution to the discipline. (Issues in Peer Review of the
Scientific Basis for Regulatory Decisions, p 5)
3.1.2 Research Direction
The ultimate purpose of the 1996 Risk Management Plan for Wet Weather Flows
is to provide the information managers need to reduce risk. The overall direction, then,
is risk reduction.
For almost two decades EPA has used the risk assessment/risk management
paradigm to organize many of its activities. ORD, for example, has reorganized itself
according to this paradigm. Risk assessment is the characterization of potential
adverse effects of exposure to environmental hazards while risk management is the
process of evaluating alternative regulatory actions and selecting among them. (NRC,
1983) Just as research is needed to better understand the nature and degree of risk,
research is also needed to provide managers with options for risk reduction. The latter
generally takes the form of research on sources, source reduction, and control
technologies. While risk managers must consider economic, political and social
constraints as well as inputs from science and engineering, a sound understanding of
the risks and options for reducing them is essential.
In FY96, the Science Advisory Board reviewed the first Strategic Plan for the
Office of Research and Development. The Board was pleased to note that the
Strategic Plan was built around the risk characterization/risk management paradigm, as
was suggested in the past by various review bodies, and includes communication as a
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necessary step. However, while the SAB perceived the use of the risk characterization
paradigm as a strength of the Strategic Plan, it also cautioned that the paradigm is
limited because of its relative inability to detect emerging environmental problems,
integrate new approaches and technologies, and address prevention of environmental
problems.
The Subcommittee recommends that the revised research plan for wet weather
flows make greater use of the risk management paradigm as an overarching framework
for linking stressors with effects and determining appropriate endpoints to be
measured. The Agency will need to be vigilant to see that research on risk reduction
options is not diminished in this process.
Further, the revised research plan should explicitly acknowledge that the
paradigm should be applied on a watershed-specific basis. The Subcommittee
believes this recommendation is consistent with The Clean Water Action Plan.
Application of the paradigm means, at a minimum, that risks and the costs and benefits
of associated risk reduction options should be quantified.
Upon review of the project mix for wet weather flows research, the Subcommittee
remains unsure about whether the current research program identifies various risk
reduction options and quantifies various costs and benefits. The Subcommittee views
the costs and benefits of the options as very important issues. While eight projects (1.4
through 1.10, 3.5) appear to be directly concerned with risk assessment, these refer
principally to "impacts" or "effects". For example, Project 4.5 (Wet Weather Flows
Physical Stressors) will report on impacts such as habitat destruction, sedimentation
and bank erosion; Project 1.7 (Small Stream Impacts) refers to receiving water
impairment; Project 1.8 (Large River Pollution) looks for impacts within a watershed;
and Project 1.9 (Evaluation of Health Risks) focuses on the persistence and fate of
pathogens and toxicants. Pathogenic contamination has been identified as the
greatest water quality threat to U.S. public health (An SAB Report: Safe Drinking
Water, Future Trends and Challenges, EPA-SAB-DWC-95-002, March 1995, First
Report from the Science Advisory Board Lookout Panel: Focus on Water Issues, EPA-
SAB-EC-LTR-97-003). Consequently the Agency is encouraged to continue and
considering expanding its research effort in the area of disinfection and pathogen
control. How the information gathered is to be translated into risk, and how these risks
are to be compared is not apparent. It appears that neither a common basis for
quantifying risk, nor common measures of risk, are being utilized. Moreover, the
assessment of costs does not appear to occupy a central position in the research plan.
Only Projects 5.1-5.7 refer directly to cost and benefits of various sorts. Those projects
which are included in the Control Technologies area (4.1-4.36) - while interesting as
possible wet weather flows control options - appear to completely ignore costs. Most
might more correctly be viewed as projects for technology demonstration, the costs and
benefits of which are of secondary importance.
8
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3.1.3 Research Coordination
The Subcommittee commends the Branch on coordinating its programmatic
efforts with other organizations such as Water Environment Federation, Water
Environment Research Foundation, and American Society of Civil Engineers. This
coordination is consistent with the stated goal (page 8) of providing information and
products to the end users (the "clients"). The Branch has developed outreach
programs to assist its clients; the Subcommittee finds that this effort is continuing at an
appropriate level.
The Subcommittee finds the following questions to be useful and suggests that
ORD use them to put wet weather flows research into an ecological risk context that
can be coordinated with programs managed elsewhere within EPA.
a) What is the current condition of the environment, and what stressors most
significantly affect the condition? (monitoring research);
b) What are the biological, chemical, and physical processes affecting the
exposure and response of ecosystems to stressors? (process and
modeling research);
c) What is the relative risk posed to ecosystems by these stressors, alone
and in combination, now and in the future? (risk assessment research);
and
d) What options are available to manage the risk to restore degraded
ecosystems (management and restoration research).
These questions are all pertinent to wet weather flows research and should be
an integral part of programmatic objectives. If wet weather flows research cannot be
placed in the ecosystems context, then the benefits of risk reduction will be ambiguous
and States and municipalities are unlikely to fund wet weather flow work. Therefore -
whether the research is conducted under the auspices of the ORD's Urban Watershed
Management Branch or supplemented by other partnerships - the wet weather flows
research should focus on the achievable and demonstrable risk reduction goals.
ORD emphasizes contaminant control technologies for wet weather flows, but
when opportunities for cooperation or collaboration exist, ORD undertakes watershed
management-oriented projects such as the Columbus, Georgia combined sewer
overflows project (4.26). This project includes assessment of receiving water benefits
provided by solids removal and disinfection. Even though such studies do not include
all stakeholders within the watershed, valuable information can be attained when
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isolated contributing sources of contaminants, and their reduction, can be assessed at
full-scale operating facilities.
3.1.4 Summary and Recommendations
The success of a research plan of the size, diversity, and complexity of the 1996
Risk Management Plan for Wet Weather Flows depends on transferring the research
findings into practice. This means the findings must be understood and applied to
reduce risk. While an important sub-set of these risk managers are EPA program and
regional staff, managers outside the Agency also make resource, policy, and other
decisions relating to reducing risk from wet weather flows. Consequently, the research
plan should be constructed such that findings and recommendations are broadly
applicable to a variety of end-users.
Risk managers find it easier to understand and apply research findings when the
results of individual projects are clearly integrated into a well-defined framework that
assists decision makers. Such decisions inevitably involve trade-offs between risk
reduction and costs. The 1996 Risk Management Plan for Wet Weather Flows lacks
overarching guidance on how the results from projects are to be used to support the
EPA Risk Management Paradigm. Thus, one of the Subcommittee's major
recommendations is that ORD develop a plan to ensure that risk reduction and costs
are fully addressed within the context of wet weather flow research activities.
10
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4. REVIEW OF THE 7996 RISK MANAGEMENT RESEARCH PLAN
FOR WET WEATHER FLOWS AND THE URBAN INFRASTRUCTURE
PLAN - WATER AND WASTEWATER ISSUES
The 1996 Risk Management Research Plan for Wet Weather Flows describes
key objectives and research questions under each of the five overarching research
areas. The document also describes on-going research that addresses these
objectives and research questions. A draft of the 1996 Plan was peer-reviewed by the
Urban Water Resources Research Council of the American Society of Civil Engineers
(ASCE) and the Water Environment Research Foundation (WERF). Comments were
also requested of over one hundred members of the Urban Wet Weather Flows
Federal Advisory Committee and its subcommittees. ORD considered the comments,
incorporating many of them, in the 1996 Plan released in November 1996.
The Subcommittee's review of the 1996 Plan considered the appropriateness of
the objectives and research questions categorized by research area. Although the
1997 Urban Infrastructure Plan had not received prior peer-review, the researchers did
invite the Civil Engineering Research Foundation to review an earlier draft. CERF
provided comments which were incorporated into the version of the plan reviewed by
the Subcommittee. The Urban Infrastructure Plan is more preliminary in nature than is
the 1996 Risk Management Research Plan for Wet Weather Flows and complements it
by detailing objectives and research needs in the fifth research area, wet weather flows
infrastructure. Findings and recommendations regarding the 1997 Plan also follow.
4.1 Findings and Recommendations: 1996 Risk Management Research Plan for
Wet Weather Flows
4.1.1 Research Objectives and Questions
The 1996 Plan addresses five logical and well-chosen areas. In this section, the
Subcommittee's comments correspond to this structure.
4.1.1.1 Characterization and Problem Assessment.
The 1996 Plan considers differences in wet weather flows between storm
events, differences in contaminants that may originate from different land-use areas,
and other sources of temporal and spatial variability. The Subcommittee recommends
that the revised plan explicitly consider temporal and spatial scales as they affect
loadings, impacts, and management.
The need to "develop and validate chemical-specific sediment quality criteria" is
critical. This is expressed under research needs in this section as the need to "Review,
improve and develop monitoring methodologies and equipment to measure the
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characteristics and impacts, including pathogenicity of wet weather flows." To properly
support this goal, specific consideration of chemical speciation, partitioning and
transport with the colloidal phases, and the bioavailability of individual species
compared with total concentrations is needed. More advanced instrumentation for on-
line analysis of pathogens, microcontaminants, and the impacts of these contaminants
(e.g., bioavailability) is needed to better quantify wet weather flow sediment
characteristics.
Relatively little is known about the origin, composition, transport, and fate of
colloids in wet weather flows. Understanding the extent, kinetics, and reversibility of
partitioning of chemicals to colloidal phases is central to understanding toxicity,
bioavailability, and persistence. Moreover, a better understanding of colloidal
processes would contribute to our understanding of "sources of sediment in urban
areas as well as the deposition and scour of sediment in sewers and channels." (1996
Risk Management Research Plan, p. 13) Descriptions of the deposition, resuspension
and mechanics of cohesive sediments remain highly empirical. The higher
concentrations of contaminants such as metals per mass of solids that are typically
observed in fine-grained sediments suggest that a better understanding of colloidal
phases in wet weather flows and the formation of cohesive sediments is needed to
better define contaminant speciation
4.1.1.2 Watershed Management
The 1996 Plan appropriately identifies the urban component as being dominant
in many watersheds, and underscores the need to analyze likely sources and
magnitudes of pollutants in a manner that is not only land-based (e.g., run-off), but also
tracks specific materials and activities. This is likely to be a productive approach that
should be augmented by a consideration of the role of overall urbanization. Issues
such as zoning, residential housing, and industrial development, as well as
transportation, and other components of the urban infrastructure should be addressed
in concert with a materials- and activity-based analysis of the sources of contaminants
in wet weather flows. The 1996 Plan also appropriately identifies the need for
estimating the atmospheric contributions (both wet and dry) of pollutants to a watershed
as a key research topic.
The Subcommittee recommends that ORD consider the role of, "non-wet
weather flows infrastructure" (e.g., atmospheric deposition), in creating or mitigating
wet weather flows and associated contaminants.
The 1996 Plan considers the impacts of physical and chemical stressors and the
assimilative capacity of urban watershed ecosystems, the interactions between
stressors, in particular combinations of physical and chemical stressors require greater
attention. An approach that considers the role of a given activity (e.g., residential
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construction or the development of non-wet weather flows infrastructure) in stressing
ecosystems, for example through changes in the urban hydrograph and accompanying
increases in sediment and contaminants, will be helpful in designing management
strategies. In coastal areas, a major (often the major) impact of wet weather flows is
depressed salinity in receiving estuaries. Such salinity dilution may be equally
important as impaired water quality for developing retention capacity for wet weather
flows.
4.1.1.3 Toxic Substances Impacts and Control
In this research area the research needs and proposed activities are well-
matched. For example, the 1996 Plan underscores the need to identify sources of toxic
substances as well as effective means or treating wet weather flows or measures to
prevent pollution. The importance of dissolved and colloidal materials and the
difficulties associated with treatment are appropriately discussed. Again, the
importance of the atmospheric sources is highlighted. Although proposed research
activities cover appropriate areas, tit is unclear that research work addressing
specifically toxic substances merit special consideration apart from other risks in wet
weather flows.
4.1.1.4 Control Technologies
The integrative approach of the 1996 Plan is appropriate and properly includes
control options that integrate with management strategies and system operation. The
1996 Plan recognizes that the highest returns in implementing new technologies are
likely to include combinations of wet weather flows routing hardware and software, as
well as acknowledges the need to develop and demonstrate high-rate treatment
technologies.
The technologies currently under investigation include several processes (e.g.,
high rate sedimentation) that appear to be poorly suited for the stormwater runoff.
Because water quality changes rapidly during storms, processes requiring the addition
of coagulants or other reactants will be handicapped by the need to determine chemical
doses. These processes will be difficult to bring on-line and adapt to changing influent
conditions. Research on control technologies should therefore focus on more robust
technologies that can be easily automated.
Conspicuously missing from the list of technologies to be evaluated are
membrane processes. The ease in automating these processes, potential cost
advantages, and the previously stated importance of dissolved and colloidal phases in
determining wet weather flows quality, suggest that membrane technologies should
also be evaluated.
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4.1.1.5 Infrastructure Improvement
Research questions and needs are notably underdeveloped in this section. ORD
recognized these weaknesses and addressed them in the 1997 Urban Infrastructure
Research Plan - Water and Wastewater Issues. The 1997 Plan is more preliminary in
nature and complements the 7996 Risk Management Research Plan for Wet Weather
Flows in detailing objectives and research needs in the fifth research area, wet weather
flows infrastructure. The Subcommittee's review appears in section 4.2 immediately
below.
4.2 Findings and Recommendations: 1997 Urban Infrastructure Research Plan
-- Water and Wastewater Issues
4.2.1 General Findings and State-of-the-Science Write-Ups
The development and execution of a research plan for wet weather flows
infrastructure is complicated by the very nature of the infrastructure. These systems
are large, complex, and often inaccessible. Experimental plans to study the system are
forced to be designed to minimize (or avoid if at all possible) any disruption of service.
Because of this, the area of infrastructure seems to have been studied the least among
the major areas identified in the 1996 Risk Management Research Plan for Wet
Weather Flows. Nonetheless, the contents in the Urban Infrastructure Research Plan -
Water and Wastewater Issues were well thought out and developed to identify and
address all major areas of research despite the lack of sufficient background materials.
However, the plan needs a sharper focus and clear links between its research
purposes and needs, as indicated below.
First, if the authors started with a well-defined research purpose and then
developed appropriate research needs that are consistent with the purpose the
research plan would be more focused and clear. This could be easily accommodated
because most of research needs were well thought out and developed in the plan; it
would require revising research questions to both state the purpose of research and
identify and develop appropriate research needs. Some suggestions on revising
research questions follow in Section 4.2.2 - Research Objectives and Questions
Second, the ultimate aims of this research plan are unclear (i.e., what does this
research aim to protect?). The plan mentions "the environment," "public health," and
"safety" without defining or prioritizing these objectives. A flow chart showing the
relationships among the purpose, aim(s), and needs could clarify this.
Third, this research plan covers a very ambitious range of issues that may
require either an expanded extramural research program to supplement its in-house
capabilities or a reduction in the scope of the plan consistent with available resources.
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4.2.2 Research Objectives and Questions
Research questions and needs should follow from a well-articulated purpose for
the research. To define the purpose, several questions should be asked. First, what is
this research plan is trying to protect? Is it water quality, public health in general, public
safety, natural resources, or if a combination, what is the prioritization? The direction of
this research plan depends on the answer to this question. The second question
should be "Why is the infrastructure system important to water quality? The answer
could be that it is because the infrastructure system stores and conveys potentially
harmful contaminants from sources to treatment facilities. Furthermore, if the capacity
and integrity of the infrastructure system are not adequate, these contaminants could
adversely affect water quality (both surface water and groundwater) through leaks and
overflows that may be harmful to human health and the environment. Although the
impact of wet weather flows on human health and the environment is not included in the
7996 Risk Management Research Plan for Wet Weather Flows, clear connections
should be made and emphasized more to strengthen the purpose of this research plan.
Once, the purpose of the research plan is clearly stated, research questions and needs
can be logically developed and prioritized to be consistent with the research purpose.
Again, this suggestion does not significantly alter the content of the plan but rather it
would help focus and clarify the plan.
4.2.2.1 Building Capacity and Maintaining Integrity.
The following comments relate to the sections:
a) Conveyance Systems - Petroleum and Chemical
b) Conveyance Systems - Stormwater and Wastewater
c) Storage Systems - Potable Water
d) Storage Systems - Petroleum/Chemical, and
e) Storage Systems - Stormwater and Wastewater.
These sections of the 1997 Plan address the best approaches to build and maintain
infrastructure systems. For example, for the section of Conveyance Systems - Potable
Water, the research question posed was "What are the best approaches to design,
construct, maintain, and rehabilitate water distribution systems and to ensure water
quality in urban settings?"
It might be more fruitful to begin with a different statement explaining why water
distribution systems are important to the quality of drinking water. This question will
lead to other questions addressing the role of the "capacity" and "integrity" of the
distribution system on water quality. Then, a series of research objectives (many of
them were already described in the plan) can be developed to address these "capacity"
and "integrity" issues.
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The "capacity" issues can incorporate overflows of chemicals, stormwater, and
sanitary wastewater, whereas the "integrity" issues can include leaks, leak detection,
groundwater infiltration, chemical and biological reactions in the system, material
specifications, construction methods, corrosion, and rehabilitation.
4.2.2.2 Hot and Chilled Water and Steam.
The section of the 1997 Plan "Conveyance Systems - Hot and Chilled Water
and Steam" was unclear on how this infrastructure system affects water and wastewater
issues other than those related to the conservation of energy and water resources.
4.2.2.3 Sustainable Development.
The 1997 Plan struggled to define the meaning of "sustainable development" in
the context of urban water and wastewater infrastructure systems. The research
question posed in the section "Sustainable Technology Development" was, "What are
the parameters associated with "sustainable" water and wastewater systems, and how
do we apply these parameters to the design, installation, operation, and maintenance
of these systems?" This question only underscores the difficulties in arriving at an
appropriate problem definition.
The 1997 Plan would benefit from using the classic definition of sustainable
development.
Sustainable development Is development that meets the needs of the
present without compromising the ability of future generations to meet
their own needs. (World Commission Environment and Development,
Our Common Future, Oxford University Press, Oxford, 1987)
Within the context provided by this framework, the plan can first define the role
of urban water and wastewater infrastructure in sustainable development and then
develop the relevant science and engineering issues associated with the role. Without
this framework, it may be premature to discuss infrastructure system research needs.
Otherwise, the Plan may simply appear to be a repackaging of old issues, such as
recycling, reuse, waste reduction, resource conservation, etc., without clearly linking
them to sustainable development.
It is important for the plan to address new infrastructure systems. Although the
Plan mentions infrastructure systems for greenfield sites, it does not discuss them at
length. This may be an area where the Plan could incorporate some or all of the
sustainable development concepts. In revising the Plan, the authors should look
toward the most environmentally and economically sustainable infrastructure systems
that can be built in the future (e.g., in the next few decades). This will define the upper
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limit of infrastructure systems. A good example of this planning process is seen in the
automotive industry's efforts to develop the next generation of power plants for
automobiles (e.g., batteries and fuel cells) replacing internal combustion engines.
Other areas that should also be considered include:
a) seasonal issues (e.g., differences between summer and winter storms);
b) regional issues (e.g., effects of road salts used in winter in the
Midwestern and Eastern states on infrastructure systems, regional
differences in storms, etc.);
c) industry-specific issues (e.g., industry-specific stormwater runoffs and
their control and, possibly EPA-industry cooperative research projects);
d) natural disasters (effects of earthquakes and floods on infrastructure
systems);
e) man-made disasters or damages (e.g., impact of possible terrorist
activities on infrastructure systems, effects of construction activities on
infrastructure systems, etc.); and
f) others (e.g., water quality changes in potable-water storage reservoir, not
tanks).
4.3 Summary and Recommendations
The five research areas are sufficiently broad to cover current and anticipated
concerns with Wet weather flows and as such are appropriate. However, there are key
issues within some of these research areas that have not been sufficiently articulated
and do not appear to be the subject of research efforts. There has been considerable
work supported under recent EPA/National Science Foundation initiatives dealing with
watersheds that should be making its way into the literature. Bibliographies and state
of the science write-ups should be updated to reflect these studies where appropriate.
Similarly, results from recent NSF initiatives on urban infrastructures should be
integrated into the research plan, particularly in the area of Infrastructure Improvement.
In all cases, research plans should highlight the need for long-term, fundamental
research that will advance our ability to regulate and monitor based on sound science.
Because the five designated research areas are so broad, almost any
combination of research projects within a limited budget is likely to fall short of meeting
all needs within a given research area. Nonetheless, the research efforts represent an
inadequate investment in defining wet weather flows problems, providing a sound basis
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for regulatory action and better decision making, and developing technologies for
monitoring and control. In the 1996 Risk Management Plan for Wet Weather Flows, the
Subcommittee has identified several areas in which specific research efforts should be
considered:
a) Differentiation between total loadings of chemical and biological
contaminants and their impacts as a basis for setting standards and
evaluating improvement;
b) Improvements in our ability to obtain real-time information on Wet weather
flow quality and quantity such as the development of pathogen-specific
sensors;
c) The temporal and spatial scaling of physical, chemical and biological
processes in wet weather flow and urban watersheds and the interactions
with neighborhood, city, county and state institutions;
d) Fundamental aspects of colloidal transport, origin, and composition,
including a better understanding of the properties of cohesive sediments;
e) Focused research on control technologies that can easily be brought on-
line during storm events without operator intervention; and
f) Impacts of wet weather flows in depressing salinities in coastal areas.
In the 1997 Urban Infrastructure Plan - Water and Wastewater Issues all major
areas were identified and addressed in a thoughtful manner. Recommendations are
made here to strengthen the plan and sharpen its focus. They are:
a) The purpose and aim(s) of research need to be clearly defined and linked
to research needs on both capacity and integrity issues of infrastructure
systems (this will also help prioritize research needs);
b) With regard to Sustainable Technology Development, engineering and
science issues on infrastructure systems need to be clearly identified
before developing detailed research needs; and
c) Additional research areas that should also be considered are
infrastructure systems for greenfield sites and impacts of seasonal and
regional differences and natural and man-made disasters on
infrastructure systems.
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5. OFFICE OF WATER NEEDS
Both the 1996 Risk Management Plan for Wet Weather Flows and 1997 Urban
Infrastructure Research Plans were released prior to the development of key Office of
Water program documents (e.g., 1998 Clean Water Action Plan, 1997-1998 Water
Agenda, 1998-1999 Water Agenda, etc.). Because of the importance of the more
recent documents, the Subcommittee has compared the two research plans with the
Office of Water documents to determine if, in fact, the correct research is being
conducted to support Office of Water's technical research needs.
The Subcommittee commends both ORD and Office of Water for having
identified and addressed many critical water-related human health and environmental
problems. The following statistics provide a sense of the scope of these problems.
a) Forty percent (40%) of the US surface waters currently do not meet water
quality goals;
b) Twenty percent (20%) of the US population is being served by drinking
water systems that are in violation of health based requirements;
c) Zero net loss rate of US wetlands has not been achieved; and
d) Wet weather flows remains the single largest contributor to water quality
impairment of US waters.
The Office of Water also cited both the 1998 Clean Water Action Plan and the
1996 Safe Drinking Water Act Amendments as providing the regulatory framework for
establishing four water related research priority areas.
a) Improvement in drinking water safety;
b) Reduction in wet weather flow pollution;
c) Protection of wetlands; and
d) Nurturing and revitalization of core Office of Water programs.
For each of the four Office of Water program priority areas, the Subcommittee
differentiated between the strategic objectives and the specific technical research
needs supporting those objectives. In many cases these relationships had to be
inferred from the very general descriptions of the research programs provided in the
Office of Water's annual research agendas. The 1996 Risk Management Plan for Wet
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Weather Flows and 1997 Urban Infrastructure Research Plan were then examined to
identify those research programs and projects that specifically address Office of Water
technical research needs summarized in Appendix D.
5.1 Findings
The Subcommittee compliments the Office of Research and Development (ORD)
for developing two technical research plans whose implementation will generate
information critical to improving US water quality. ORD's decision to focus a
substantial part of its efforts on investigating methods to reduce pathogenic
contamination is particularly well-considered; such contamination is the greatest water
quality threat to US public health. ORD also correctly recognized that air deposition
can be a significant mechanism of water quality impairment.
The Subcommittee commends ORD for highlighting key infrastructure issues
facing the US in the area of water supply and water quality protection. Unfortunately,
because the Office of Water has not identified these issues as research priorities,
research results may have less immediate impact than might otherwise be the case.
The Subcommittee believes that the Office of Water technical research needs
can be better addressed by the following.
a) The 1998 Clean Water Action Plan clearly recognizes the unique nature
of water issues associated with tribal lands and intends to expand the
efforts of Office of Water's Tribal Strategy to implement the National
Water Program in Native American communities. Therefore, substantial
research efforts directed specifically at addressing water issues involving
Native American communities should be added. In some instances, water
quality issues associated with tribal lands are substantially different from
those facing other parts of the US. These differences are particularly
apparent when addressing the issues of total maximum daily loads
(TMDLs) and drinking water system management.
b) The 1996 Risk Management Plan for Wet Weather Flows is silent on
public involvement. In contrast, Office of Water recognizes that public
involvement must be an integral part of all environmental protection
decision-making; this commitment is illustrated by the expansion of public
access to water quality related information and through citizen's right-to-
know activities. Incorporation of the various interests can expand our
understanding of potential risks and risk reduction options and otherwise
ensure program success. Unfortunately, none of the projects or programs
cited in the 1996 Risk Management Plan for Wet Weather Flows address
this critical issue in either their development or implementation.
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The Subcommittee encourages ORD to develop and employ a research
planning process that involves all stakeholders (i.e., all parties with an
interest in the outcome of the research efforts) at the initial phase of
research program development. One resource for planning such
involvement might be the EPA's Environmental Technology Verification
program which has acquired significant experience involving stakeholders
on technology issues by involving over 650 stakeholders in fifteen groups.
The Data Quality Objectives (DQO) process can facilitate public
involvement during the research planning stage. This process is
described in Guidance for the Data Quality Objective Process EPA QA/G-
4 (EPA/600/R-96/055) and Guidance for Quality Assurance Project Plans
EPA QA/G-5 (EPA/600/R-98/018). The DQO process outlines the
method(s) by which decision-makers can integrate stakeholder concerns
within the research program and project development. Employing the
DQO process in this manner ensures that the correct research projects
will be undertaken to generate the appropriate data of the sufficient
quality to satisfy both the decision-maker(s) and stakeholder needs. The
application of the DQO process in the overall program management is of
critical importance in insuring results that satisfy the broadest and most
pressing needs in an economic fashion. The Agency is strongly
encouraged to implement the DQO process early and broadly in program
and project development.
c) Although the 1996 Risk Management Plan for Wet Weather Flows
highlights the technical efforts within the watershed restoration and
management program, watershed research projects do not sufficiently
address non-urban wet weather flow issues. Moreover, while ORD's
emphasis on control of point sources of pollution (e.g., sanitary sewer
overflows, combined sewer overflows, etc.) is important to watershed
restoration and management, the small number of projects that focus on
developing methods to manage and control nonpoint source pollution
suggests a potential imbalance in program priorities.
d) From program descriptions included in both the 1998 Clean Water Action
Plan and the 1998-1999 Office of Water Agenda, the Office of Water
clearly recognizes the importance of managing the discharges of nonpoint
source pollution into US waters. To address this issue, Office of Water
has expanded its efforts in developing regulatory controls on discharges
associated with concentrated animal feeding operations and stormwater
together with expressing the need for the development of risk assessment
tools for managing environmental quality of watersheds.
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5.2 Recommendations
The Subcommittee encourages ORD to use a more formal process through
which research programs and projects that address the technical research needs of
individual program offices may be identified. Balancing Office of Water technical
research needs, which include a strong programmatic focus on nonpoint source
pollution issues, with ORD's present emphasis on point source pollution control reflects
the urgency for developing a more formal process to coordinate ORD program
development with that of the individual program offices. To facilitate the integration of
future ORD research plan development with Office of Water technical research needs,
the Subcommittee recommends:
a) ORD develop a more formal process by which its research projects and
programs can be synchronized with Office of Water technical research
needs. The process should be transparent and include timetables that
specify submission dates for Office of Water research program technical
needs together with a description of the methodology used by Office of
Water to prioritize technical needs. Finally, the process should include a
mechanism that will enable ORD to characterize measurable progress in
order to meet its obligations under the 1993 Government Performance
and Results Act (GPRA).
b) In order to apply its limited resources in a cost-effective manner, ORD
should develop a transparent methodology to prioritize its programs and
projects. The methodology should include an objective rationale for
prioritization based on the risk management paradigm.
c) For each research project, ORD should identify the set of metrics that will
be employed to evaluate the extent to which progress is being made in
addressing Office of Water needs. These metrics should be directly
applicable and easily convertible to the reporting requirements of GPRA.
d) ORD should formally adopt the DQO process in its program and project
development to ensure that the interest of all relevant stakeholders will be
considered. In addition, the DQO process will result in conserving limited
ORD resources by ensuring that the data collection activities will be
precisely those required to address the water quality decisions that have
to be made. Finally, to adequately address the increasing number of
challenges the Agency will face regarding the scientific basis for its
rulemaking, linking data quality to environmental decisions is paramount.
e) To enable ORD to be more responsive in meeting Office of Water
technical research needs, the characteristics of the water problem to be
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investigated should be clearly defined by Office of Water and should
include technical and/or regulatory decisions that depend on data
generated. By identifying technical and/or regulatory decisions
associated with particular water issues, ORD may better structure its
research programs to determine the specific data types to be collected
and the level of data quality required to make appropriate decisions.
f) To correct the omission in its research plan related to tribal issues, ORD
is encouraged to develop water related research programs that are
broadly based and whose results would be applicable to tribal lands as
well as other areas of the US.
g) In an effort to remedy the lack of work related to nonpoint sources, ORD
should consider developing research programs that are more
comprehensive in scope and that would address both point and nonpoint
pollution contributions to watershed impairment. For example, a research
program focused on nutrient control must include point source discharges
from sanitary sewers, wastewater treatment plants as well as nonpoint
source contributions from stormwater and run-off from agricultural
fertilizer and animal feed operations.
h) Finally, the relative risk to environmental integrity from wet weather flows
must be systematically apportioned at the watershed level between rural
(agricultural) and urban components. To facilitate this linkage, research
at the watershed level must be directed, in both rural and urban sectors,
and at establishing surface water - ground water interactions as a
prerequisite to developing protocols for mediating and processing wet
weather flows.
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APPENDIX A: Expanded Charge for the Review
Project Title/Subject: EPA's Risk Management Research Program for Wet
Weather Pollution Control
Expanded Charge: Evaluate the scientific directions (are we doing the right
science/engineering research?) and scientific quality (are we doing our
science/engineering research right?) of EPA's Wet Weather Flow (WWF) research
program, including our Urban Infrastructure research. In doing this evaluation, take
into account what research others (including WERF and ASCE) are doing in these
areas, what OWs needs are, and ORD/NRMRL's resource constraints.
Review the 1996 Risk Management Plan for Wet Weather Flows and the 1997
Urban Infrastructure Research Plan - Water and Wastewater Issues with special
emphasis on the state of the science writeups, research questions, and research
needs. Comment on the appropriateness of having five WWF research areas:
characterization and problem assessment, watershed management, toxic substance
impacts and control, control technologies and infrastructure improvement. Comment on
the completeness and currency of the research plan bibliographies. Determine the
adequacy of the infrastructure research program to meet the wastewater infrastructure
needs of the OW-OWM and the drinking water infrastructure needs of the OW-
OGWDW.
Determine if the projects cited in the research plans fulfil the research needs.
Specifically, review the water program's priorities and needs and determine to what
extent the ORD research program supports those needs. The OW needs are
contained in the 1999 Water Agenda and the materials from the last water program
review (where Fred Lindsey, Deputy Director of OWM, expressed OWM's needs).
Evaluate ongoing ORD urban infrastructure research projects, especially those of the
NRMRL-Water Supply and Water Resources Division, vis-a-vis wastewater systems,
drinking water systems and potential public health impacts to determine if they meet the
needs of the OW-OGWDW.
Determine the extent to which the EPA research program complements (or
competes with) other research programs, such as that embodied in the Water
Environment Research Foundation (WERF) "Research Needs in Urban Wet Weather
Flows (Feb 98)" plan. Compare the work WERF is doing under the EPA grants they've
received for the last two fiscal years with WWF research being done by others.
Comment on the concept of using Watershed Management research as a unifying
concept/organizing principle for coordinating the research efforts of the applicable
National Risk Management Research Laboratory divisions and branches.
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APPENDIX B: DOCUMENTS REVIEWED
1. Briefing Outline "BRIEFING FOR SCIENCE ADVISORY BOARD WET
WEATHER FLOW RESEARCH PROGRAM, December 1998" with attachments:
1 - "Urban Watershed Management Branch - Branch Plan - FY98",
November 18, 1997
2 - WWF Research Plan - "Risk Management Research Plan for Wet
Weather Flows", EPA/600/R-96/140, November 1996
3 - "Urban Infrastructure Research Plan - Water and Wastewater Issues",
January 1997
4 - "FY98 UWMB Operations Plan", 9/29/98, "FY97 UWMB Operations
Plan", 9/29/98,
5 - UWMB Manning Chart, 11/13/98
6 - "UWMB Active Projects as of July 9, 1998"
7 - "UWMB Progress Report for July-September 1998", November 9, 1998
8 - "Urban Watershed Research Facility - Building and Facilities Project #1 -
January 1998" and "Urban Watershed Research Facility - Building and
Facilities Project #2 - September 1998"
9 - "Urban Watershed Research Facility - Statement of Work - Support
Contractor", August 1998
10 - UWMB FY98 Publications, September 8, 1998
2. Memorandum, "Wet Weather Project Information" from Jeffrey Moeller at Water
Environment Federation, December 22, 1998
3. Note to SAB Review Team re "SAB Expanded Charge", January 12, 1999
4. Note to SAB Review Team re "Background Materials", January 11, 1999 with
enclosures:
B:i - WERF "Research Needs in Urban Wet Weather Flows" Feb 98
B:ii - OW 1999 Water Agenda - "National Water Program Agenda, 1998-1999"
June 10, 1998 memorandum
B:iii - OW 1998 Water Agenda - "National Water Program Agenda, 1997-1998"
B:iv - "Water Research Strategic Review - Crystal Gateway Marriott, Arlington,
Virginia - January 20, 1998"
B:v - Research Needs Article - "Urban Wet Weather Flow Management:
Research Directions", Field et al, Journal of Water Resources Planning
and Management, May/June 1998; WEF Literature Review - "1998
Literature Review - Urban wet-weather flows", Field et al, Water
Environment Research, V70, N4, June 1998; WEF Literature Review -
"1997 Literature Review - Urban wet-weather flows", Field et al, Water
Environment Research, V69, N4, June 1997; WEF Literature Review -
"1996 Literature Review - Urban wet-weather flows", Field et al, Water
B-1
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Environment Research, V68, N4, June 1996; and UWMB
Publications/Presentations for FY97, FY98, FY99
B:vi - UWMB Description of WWF Internet Home Page
B:vii - List/Short Description of Projects Given under WERF Cooperative
Agreement (reference to Grants given under 104b3 program is incorrect)
"Water Environment Research/Demonstration Wet Weather Projects",
12/22/98
4. Widespread Failure to Comply with U.S. Storm Water Regulations for Industry,
Part 1: Publicly-available data to estimate number of potentially regulated
facilities, and
Part 2: Facility-level evaluations to estimate number of regulated facilities
5. Equalizing, Civil Engineering, January 1999, pages 56-59
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APPENDIX C:Wet Weather Flows and Urban Infrastructure Research
Plan Review Team Assignments
Overall guidance and direction: D. Grasso, chair
Team Members
Chuck Noss
Tom Theis
Assignment
Evaluate Program scientific direction & quality
Evaluate coordination with Water Environment
Research Foundation (especially EPA grants to
Water Environment Research Foundation over
last two years)
Comment on Watershed Management as a
unifying concept/organizing principle
Byung Kim
Mark Wiesner
Review Risk Management Plan , Wet weather
flow of Water s & Urban Infrastructure Plan,
Water & Wastewater Issues
Specifically for
State-of-the-science write-ups
Research questions and needs
Appropriateness of five areas of research areas
Currency of research plan & bibliography
Adequacy of infrastructure research program to
meet water (Office of Water -OGWDW) &
wastewater (Office of Water -Office of Water M)
infrastructure needs
L.D. McMullen
Mike McFarland
Review Water Program's priorities and needs
Do projects meet research needs?
Does ORD research program support needs?
Do ongoing ORD infrastructure projects meet
needs?
C-1
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APPENDIX D: Summary of Research Programs and Projects that
Specifically Address Office of Water Technical Research Needs
Improvement in Drinking Water Safety
The overarching goal of Office of Water with regard to improvement in drinking
water safety is the implementation of the 1996 Safe Drinking Water Act Amendments
(SDWA). To achieve this goal, Office of Water identified the following priorities:
1. source water assessment and protection
2. coordination of infrastructure financing
3. watershed management
4. citizen's right to know
With regard to source water assessment and protection, the drinking water
program has established protecting human health from microbiological contaminants
and disinfectant/disinfection by-products as well as from critical chemical contaminants
(e.g., arsenic and radon) as its most immediate concerns. To address these concerns,
Office of Water developed the following strategic objectives:
1. creation of teams consisting of EPA, state officials, tribes and public work
groups such as the National Drinking Water Advisory Council (NDWAC)
to develop safe drinking water implementation strategies,
2. provide guidance to states on source water protection and assessment,
3. encourage integration of source water protection efforts with watershed
management programs and
4. improvement of public water systems management capacity through
issuing program guidance for drinking water system training and
certification.
The following technical research needs were identified by Office of Water to
address the strategic objectives for source water assessment and protection:
1. Develop and provide tools to water suppliers and communities to assess
the conditions of local water resources and to link clean water and
drinking water protection programs (e.g., Total Maximum Daily Loads -
TMDLs).
2. Develop and promulgate interim water quality standards for microbial
contaminants, arsenic and radon as well as regulations for disinfection
by-products.
3. Develop a comparative risk framework for assessing microbial disinfection
by-products (M/DPBs).
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4. Develop tools for small communities to address the new monitoring
requirements of the 1996 Safe Drinking Water Act Amendments (SDWA).
In addition to source water assessment and protection, Office of Water
identified the coordination of infrastructure financing as critical to the successful
implementation of the 1996 Safe Drinking Water Act Amendments. Specifically, the
efforts of Office of Water to coordinate infrastructure financing focus primarily on
assisting states in developing revolving loan fund programs to support needed drinking
water infrastructure projects. In concert with this effort, Office of Water has stated its
intent to collaborate with states and interstate agencies to revise the Section 106-grant
allocation formula. The formula will be revised to account for the specific
characteristics of the drinking water issue in financial resource allocation.
Although no specific technical research needs were identified as necessary by
Office of Water to facilitate the coordination of infrastructure financing, any revision of
the Section 106-grant allocation formula to reflect specific characteristics of a drinking
water issue would involve technical considerations. Therefore, Office of Water is
encouraged to provide a description of the method by which the grant allocation
formula will be revised and to identify the possible uncertainties for which technical
research may be warranted.
With respect to improving drinking water safety through watershed management,
Office of Water has adopted a watershed approach to control point and nonpoint
source pollutant discharges considering:
1. drinking water sources,
2. ground water protection and
3. protection and restoration of habitat (e.g., wetlands).
Moreover, the watershed approach will be employed as a mechanism for
implementing Clean Water Act (CWA) responsibilities. Key elements of the watershed
approach include:
1. unified watershed assessments,
2. strong state and federal standards,
3. watershed restoration action strategies,
4. watershed pollution prevention and
5. watershed assistance grants.
Finally, to assist states and tribes in identifying impaired watersheds as required
under Section 303(d) of the Clean Water Act (CWA), Office of Water strategic
objectives include the evaluation of pollution control tools (e.g., water quality criteria,
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risk assessment methods, educational materials etc.) that are most appropriate to
characterize watershed quality.
To meet its strategic objectives, the following technical research needs were
identified by Office of Water:
1. Improvement and evaluation of technical tools for rapid and accurate
assessment of watershed pollution loadings through reinvention of the
Total Maximum Daily Load (TMDL) program.
2. Assessment of the condition and vulnerability of each of the 2,000 plus
US watersheds through the National Watershed Assessment Project.
3. Development of indicators to measure ecological conditions of
watersheds and stressors
4. Development of landscape analysis approaches to describe the
relationship between land cover and water quality
5. Development of best management practices (BMPs) for key sources of
watershed impairment
With regard to improving drinking water safety through expansion of citizen's
right to know , Office of Water has stated its intent to promote access to watershed
quality information by the general public. Examples of promoting this goal cited by
Office of Water include the:
1. continued development of the communications tool Surf Your Watershed
(located on Office of Water Internet Homepage) and
2. promulgation of regulations requiring annual consumer confidence reports
be issued by drinking water suppliers to the public.
No specific technical research needs were identified as necessary by Office of
Water to facilitate these efforts.
Reduction in Wet Weather Flow Pollution
Since wet weather flows have been identified as the single largest threat to
water quality impairment in the US, Office of Water has stated its intent to work with
states, tribes, local government and the Urban Wet-Weather Advisory Council to
assure the coordinated development of policies relating to urban wet weather pollution.
Office of Water has identified the following strategic objectives as critical to achieving
effective urban wet weather pollution control:
1. development of proposed regulations and guidance to streamline the
Phase I permit program,
2. publishing a new national policy to improve control of sanitary sewer
overflows and
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3. integration of stormwater pollution controls with other pollution controls on
a watershed basis.
With regard to non-urban wet weather flows, Office of Water has proposed
collaborative efforts with other federal agencies (e.g., US Department of Agriculture) to
develop strategies further reducing water pollution from nonpoint sources including the
development and implementation of Best Management Practices. Furthermore, as
agriculture has been identified as the principle source of nonpoint source pollution
discharges to US rivers, Office of Water has developed strategic objectives specifically
designed to address agricultural pollution abatement including:
1. collaboration with the Office of Compliance and Enforcement Assurance
(OCEA) to assess the extent to which concentrated animal feeding
operations (CAFOs) are in compliance with the National Pollutant
Discharge Elimination System (NPDES) program,
2. evaluation of the necessity to expand permitting requirements to include
animal feeding operations that have the potential to significantly impact
water quality,
3. strengthening national guidelines to reduce water quality impacts of
CAFOs, and
4. developing national minimum standards for water quality assessments of
nontraditional sectors such as concentrated animal feeding operations
and stormwater.
To achieve these strategic objectives, the following technical research needs
were identified by Office of Water:
1. Development of water quality standards (including chemical specific and
whole effluent toxicity criteria) to apply to extreme wet weather events
2. Development of site specific water quality criteria techniques for
establishing TMDLs
3. Development of better acquisition methods for obtaining reliable land use
data
4. Development of monitoring plans to quantify point and non-point sources
within watersheds
5. Development and validation of models to address cross media concerns
6. Development of scientific tools to facilitate watershed scale risk
assessments (e.g., development of specific water quality indicators)
7. Evaluation of the impact of wet weather flows on the development of
hazardous algal blooms
Protection of Wetlands
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Office of Water has stated that protection and restoration of US wetlands will be
guided by the new Wetlands Program Strategic Plan. Key Office of Water activities to
protect and restore wetlands include:
1. developing guidance to ensure the long term success of wetlands
mitigation projects including mitigation banking and
2. strengthening partnerships with other federal agencies to increase the
rate of wetlands restoration.
Office of Water will continue to facilitate coordination between the US Army
Corps of Engineers, states, and tribes in the recently reissued nationwide wetland
permit program in order to slow the rate of wetland loss.
Although Office of Water strategic objective for protection of wetlands is to
reverse the current trend of net wetland loss, no specific technical research needs to
achieve this reversal were cited within the annual water agendas.
Nurturing and Revitalizing Core Programs
Office of Water has recognized the need to provide a balance between
increased flexibility in program implementation with continued progress in improving
accountability for program results by measuring real changes in the environment.
Since the success of the water programs will be measured by the environmental and
public health outcomes, Office of Water will continue to work with tribes, states and
local governments to create a system of environmental protection based on
accountability and measurable progress. The 1993 Government Performance and
Results Act (GPRA) and the National Performance Partnership (NEPPs) will provide
the necessary framework for planning and accountability.
To achieve measurable progress within the water priority areas, Office of Water
has determined that the new initiatives must be integrated within a set of strongly
supported core environmental protection programs. The strategic objectives developed
by Office of Water to nurture and revitalize these core environmental protection
programs include:
1. collaborating with stakeholders to develop a strategy to address toxic
pollutants with development and reproductive health effects in conjunction
with recommendations from the National Academy of Sciences,
2. publishing national guidelines for state certification programs,
3. working with Office of Water Tribal Strategy to implement the National
Water Program on tribal lands,
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4. assessing issues related to airborne deposition of pollutants to US
waters,
5. developing approaches to control pollution on a watershed basis,
6. working with states to develop regulations for chemical contaminants in
drinking water, and
7. supporting water program areas with sound peer reviewed science.
To achieve these strategic objectives, the following technical research need was
identified by Office of Water: development of tools to support priority setting, risk
assessment and risk management.
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REFERENCES
Issues in Peer Review of the Scientific Basis for Regulatory Decisions, American
Chemical Society and The Conservation Foundation, 1985.
NRC. 1983. Risk Assessment in the Federal Government: Managing the Process,
Committee on the Institutional Means for Assessment of Risks to Public Health,
Commission on Life Sciences, National Research Council, National Academy
Press, Washington DC
SAB. 1995. An SAB Report: Safe Drinking Water, Future Trends and Challenges.
Drinking Water Committee. (EPA-SAB-DWC-95-002) Washington DC
SAB. 1996. Review of the Strategic Plan for the Office of Research and Development
by the Research Strategies Advisory Committee (RSAC) of the Science Advisory
Board. Research Strategies Advisory Committee. (EPA-SAB-RSAC-LTR-96-
004) Washington DC
SAB. 1997. First Report from the Science Advisory Board Lookout Panel: Focus on
Water Issues. Executive Committee. (EPA-SAB-EC-LTR-97-003) Washington
DC
USDAandUSEPA. 1998. Clean Water Action Plan.
(http://www.epa.gov/cleanwater/action/toc.html) Washington DC
USE PA. 1996. Guidance for the Data Quality Objective Process EPA QA/G-4
(EPA/600/R-96/055) Washington DC
USE PA, 1998. Guidance for Quality Assurance Project Plans EPA QA/G-5
(EPA/600/R-98/018) Washington DC
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United States Science Advisory Board EPA-SAB-EEC-99-019
Environmental Washington, DC September 1999
AN SAB REPORT: REVIEW
OFTHE1996R/SK
MANAGEMENT PLAN FOR
WET WEATHER FLOWS
ANDTHE1997KRBAA/
INFRASTRUCTURE
RESEARCH PLAN
REVIEW BY THE
WET WEATHER FLOWS AND
URBAN INFRASTRUCTURE
SUBCOMMITTEE OF THE
SCIENCE ADVISORY BOARD'S
ENVIRONMENTAL ENGINEERING
COMMITTEE
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