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U.S. Environmental Protection Agency
Office of Inspector General
At a Glance
14-P-0363
September 29, 2014
Why We Did This Review
We evaluated the effectiveness of
the U.S. Environmental Protection
Agency's (EPA's) programs in
preventing and addressing
contamination of surface water
from hazardous chemicals
passing through publicly owned
treatment works (hereafter
"sewage treatment plants").
Hazardous wastes, regulated by
the EPA, may be harmful to
human health or the environment.
Sewage treatment plants receive
permits, from the EPA or states,
for discharges to surface waters
that establish pollutant monitoring
requirements. However,
hazardous chemicals discharged
to sewers are not regulated under
EPA hazardous waste regulations.
Rather, they are regulated under
the Clean Water Act, which
focuses on a list of 126 priority
pollutants that does not include
many hazardous chemicals.
This report addresses the
following EPA goals or
cross-agency strategies:
	Protecting America's waters.
	Ensuring the safety of
chemicals and preventing
pollution.
	Protecting human health and
the environment by enforcing
laws and assuring
compliance.
Send all inquiries to our public
affairs office at (202) 566-2391 or
visit www.epa.gov/oia.
The full report is at:
www.epa.gov/oig/reports/2014/
20140929-14-P-0363.pdf
More Action Is Needed to Protect Water Resources
From Unmonitored Hazardous Chemicals
What We Found
Management controls put in place by the EPA to
regulate and control hazardous chemical
discharges from sewage treatment plants to
water resources have limited effectiveness. The
EPA regulates hazardous chemical discharges to
and from sewage treatment plants, but these
regulations are not effective in controlling the discharge of hundreds of
hazardous chemicals to surface waters such as lakes and streams. Sewage
treatment plant staff do not monitor for hazardous chemicals discharged by
industrial users. This is due to a general regulatory focus on the priority
pollutants list that has not been updated since 1981, limited monitoring
requirements, limited coordination between EPA offices, a lack of tracking
hazardous waste notifications required for submittal by industrial users, or a
lack of knowledge of discharges reported by industrial users under the Toxics
Release Inventory. Except for EPA Region 9, sewage treatment plant permits
generally include very few monitoring requirements or effluent limits, which can
limit enforcement actions.
The EPA developed whole effluent toxicity test results as a mechanism to
identify toxic chemicals such as hazardous discharges to sewage treatment
plants. However, these are not required for all permits, and are not tracked by
the EPA to verify that sewage treatment plants are reporting results as
required. Moreover, exceedances of chemical limits in permits and toxicity
tests do not trigger notification to enforcement programs. Consequently, the
EPA may not be aware of chemical discharge or toxicity exceedances that
should be addressed to minimize potentially harmful contamination of water
resources.
Recommendations and Planned Agency Corrective Actions
We recommend that the EPA develop a format for sharing annual Toxics
Release Inventory data, develop a list of chemicals beyond the priority
pollutants list for inclusion in permits, confirm compliance with the hazardous
waste notification requirement, and track required submittals of toxicity tests
and violations. The agency suggested a change to one recommendation,
which the OIG accepted. All recommendations are resolved.
Noteworthy Achievements
The EPA has designed the Discharge Monitoring Report Pollutant Loading
Tool to provide access to surface water discharge and other data.
EPA does not have
mechanisms to address
discharge of hazardous
chemicals into water
resources.

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