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Office of Inspector General
Central Audit Division
Audit Report
WATER
Improvements to Louisiana's Water Quality
Standards, Monitoring, and Reporting Program
Would Better Protect State Waters
Report No. 2000-P-2000185-00022
September 29, 2000

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Inspector General Division:
Central Audit Division
Dallas, Texas
Region Covered:
Program Office Involved
Audit Contributors:
Region 6
Water Quality Protection Division
Angela Bennett, Team Leader
Les Partridge, Auditor
Gerry Snyder, Engineer
Randy Holthaus, Audit Manager

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September 29, 2000
MEMORANDUM
SUBJECT: Improvements to Louisiana's Water Quality Standards,
Monitoring, and Reporting Program Would Better Protect State Waters
Report No. 2000-P-000185-00022
FROM:	Randy P. Holthaus
Audit Manager
Dallas Office
TO:	Gregg Cooke
Regional Administrator
Region 6
Attached is our report entitled Improvements to Louisiana's Water Quality Standards,
Monitoring, and Reporting Program Would Better Protect State Waters. We discussed our
findings with your staff and issued a draft report. We summarized your comments in the final
report and included your complete response in Appendix I.
We appreciate the cooperation of your staff and the assistance provided throughout the
audit. The staff exhibited a genuine interest in working with us to improve the water quality
program and helped add value to this audit.
ACTION REQUIRED
In accordance with Environmental Protection Agency (EPA) Order 2750, you, as the
action official, are required to provide this office a written response to the audit report within 90
days of the final audit report date. For corrective actions planned but not completed by the
response date, reference to specific milestone dates will assist in deciding whether to close this
report.
This audit report contains findings that the Office of Inspector General (OIG) has
identified and corrective actions OIG recommends. This audit report represents the opinion of
OIG, and the findings in this audit report do not necessarily represent the final EPA position.

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Final determinations on matters in this audit report will be made by EPA managers in accordance
with established EPA audit resolution procedures.
We have no objections to the release of this report to the public. If you have any
questions, please call me at (214) 665-6620. Please refer to report number 2000-P-000185-
00022 on any correspondence.
Attachment

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Improvements to Louisiana's Water Quality Standards, Monitoring
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EXECUTIVE SUMMARY
PURPOSE	Maintaining clean and safe water is one of the
Environmental Protection Agency's (EPA) 10 strategic
goals. This audit is one in a series of state water quality
audits conducted by the Office of Inspector General to
develop a national picture of the performance of state water
quality programs.
The overall objective of the audit was to determine whether
Louisiana had developed and effective water quality
program that protects State waters. The objectives of the
audit were to determine whether: (1) Region 6 maintained
effective and adequate oversight of Louisiana's program;
(2) Louisiana developed water quality standards that would
protect State waters; (3) Louisiana monitored and assessed
the quality of all appropriate waters in the State; and (4)
Louisiana developed water quality reports that were
complete, accurate, and useful.
RESULTS IN BRIEF	Region 6 generally implemented effective procedures to
approve and evaluate Louisiana's water quality standards.
The Region's oversight of the State's monitoring program,
however, was limited because the Region had not made a
formal evaluation of the adequacy of the program relative to
the monitoring requirements of §106 of the Clean Water
Act and the reporting requirements of §305(b). The
Region's ability to evaluate the program was limited by
Louisiana's untimely and incomplete water quality planning
documents.
Louisiana's water quality program was strong in some
areas, but needed improvements in others to better protect
State waters. Although Louisiana was proactive in the
development and adoption of water quality criteria, the
standards setting process could be improved by: (1) using
more sensitive test methods than currently used to
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assess water quality needs; (2) adopting EPA recommended
bacteria criteria; and (3) clarifying procedures in the
State's antidegradation implementation plan.
Louisiana could improve its monitoring and assessment
program with the use of biological monitoring, and updated
and complete water quality planning documents. The water
quality reports issued by Louisiana of its monitoring and
assessment activities were submitted as required.
RECOMMENDATIONS	We recommend that the Regional Administrator consult
with the Office of Water regarding guidance that would
require permittees to use the most sensitive test methods
and establish national guidance on antidegradation
implementation plans.
We also recommend that the Regional Administrator
negotiate §106 grant commitments with Louisiana in
clarifying its antidegradation implementation plan, adopting
EPA's recommended bacteria criteria, and implementing
biological monitoring.
AGENCY AND STATE	Region 6 generally agreed with the findings and
COMMENTS AND	recommendations. The Region provided comments to
OIG EVALUATION	clarify portions of the report, and we have incorporated
these comments and modified the report as appropriate. We
have summarized the Region's comments following each
chapter and have included the complete response in
Appendix I.
Louisiana generally did not agree with our findings and
recommendations. Louisiana's comments were considered
and the report was modified as appropriate. We have
summarized Louisiana's comments following each chapter.
Because of significant modifications made in the report
subsequent to receipt of the State's response, the complete
response is not included in the final report. The State's
complete response is available upon request.
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TABLE OF CONTENTS
Page
EXECUTIVE SUMMARY	i
CHAPTERS
1	INTRODUCTION	1
PURPOSE	1
OBJECTIVES 	1
BACKGROUND	2
SCOPE AND METHODOLOGY 	7
PRIOR AUDIT COVERAGE 	7
2	REGION 6 OVERSIGHT OF LOUISIANA'S
MONITORING PROGRAM WAS LIMITED	8
EFFECTIVE OVERSIGHT OF WATER QUALITY
STANDARDS PROGRAM	8
LIMITED OVERSIGHT OF MONITORING PROGRAM 	8
CONCLUSION	9
RECOMMENDATIONS	9
AGENCY AND STATE COMMENTS AND OIG EVALUATION	10
3	IMPROVEMENTS TO WATER QUALITY STANDARDS WOULD ENSURE
FURTHER PROTECTION OF STATE WATER QUALITY 	11
ADOPTING CRITERIA IN THE ABSENCE OF EPA CRITERIA	11
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USING MORE SENSITIVE TEST METHODS IS NEEDED
TO BETTER ASSESS WATER QUALITY NEEDS	12
ADOPTING E. COLI AND/OR ENTEROCOCCI CRITERIA
WOULD MEET EPA REQUIREMENTS 	14
CLARIFYING PROCEDURES WOULD STRENGTHEN
ANTIDEGRADATION IMPLEMENTATION PLAN	15
CONCLUSION	16
RECOMMENDATIONS	16
AGENCY AND STATE COMMENTS AND OIG EVALUATION	17
4 WATER QUALITY MONITORING AND ASSESSMENT
PROGRAM COULD BE IMPROVED	19
BIOLOGICAL MONITORING WOULD ENHANCE PROGRAM	19
WATER QUALITY PLANNING DOCUMENTS NOT
UPDATED OR COMPLETE 	20
WATER QUALITY REPORTS SUBMITTED AS REQUIRED	22
CONCLUSION	23
RECOMMENDATIONS	23
AGENCY AND STATE COMMENTS AND OIG EVALUATION	23
EXHIBITS
1	SCOPE AND METHODOLOGY 	26
2	PREVIOUS OIG WATER QUALITY REPORTS	27
3	POLLUTANTS REQUIRING THE USE OF MORE
SENSITIVE TEST METHODS 	28
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APPENDICES
I	AGENCY RESPONSE 	29
II	ABBREVIATIONS	33
III	DISTRIBUTION	34
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CHAPTER 1
INTRODUCTION
PURPOSE	Water is one of our vital resources and must be protected.
Clean and safe water is one of the Environmental Protection
Agency's (EPA) 10 strategic goals. This goal includes
ensuring our surface waters, such as lakes, rivers, wetlands,
and oceans sustain human health; support and maintain
aquatic life; and provide for both recreational and economic
activities. EPA and the states have developed water quality
programs to protect surface waters by designating use
classifications, setting criteria to protect
the use, and then monitoring and reporting on how well
the water quality supports the use. EPA and states use
their water quality information as a basis for, and to
measure performance of, their programs to control and
clean up water pollution. This audit is one in a series of
state water quality audits conducted by the Office of
Inspector General (OIG) to develop a national picture of
the performance of state water quality programs.
OBJECTIVES	The overall objective of the audit was to determine whether
the Louisiana water quality program effectively protects
public health and the environment by supporting safe
drinking water sources, fish consumption, safe recreation,
and healthy aquatic life use designations. Our specific
objectives were to determine whether:
P Region 6 implemented effective procedures to
approve Louisiana's water quality standards and
evaluate the State's water quality standards setting,
monitoring, and reporting program;
P Louisiana developed water quality standards that
will protect the State's water quality;
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P Louisiana monitored and assessed the quality of all
appropriate waters in the State; and
P Louisiana developed reports on water quality that
were complete, accurate, and useful for program
management.
BACKGROUND	The Clean Water Act (the Act) is the primary legislation
addressing water quality programs. The objective of the
Act is to restore and maintain the quality of the nation's
surface waters. The Act gave EPA the responsibility for
developing water quality criteria for priority pollutants to
protect human health and aquatic life. Federal regulations
place responsibility on states to adopt water quality criteria
which are an important basis for states to protect designated
uses of a waterbody. Water quality standards consist of
three elements: designated use classifications, criteria
necessary to protect the designated uses, and an
antidegradation policy.
Use Requirements	States classify waters according to how they can be used,
such as for drinking, fishing, and swimming. Multiple use
classifications can be assigned to individual waters. The
goal of the Act is that all waters of the United States, where
attainable, be fishable and swimmable. The fishable use
provides for the protection and propagation of fish,
shellfish, and wildlife. The swimmable use provides for
recreation in and on the water. In accordance with the
goals of the Act, states are required to adopt the fishable
and swimmable use classifications for all waters, unless the
water cannot meet these uses. If the waters cannot meet
these uses, states are required to conduct special studies
showing the uses are not attainable, in accordance with 40
Code of Federal Regulations (CFR) 131.10, Designation of
uses.
Criteria Requirements	Once use classifications are assigned, states are required to
adopt criteria in their water quality standards to protect the
designated uses. Numerical criteria identify the amount of a
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specific pollutant that may be present in the water and still
protect the designated use. Narrative criteria may also be
used to protect uses if numerical criteria is not available or a
specific pollutant cannot be identified as the cause of use
impairment.
EPA develops and publishes criteria that set limits for
pollutants based on the effect the pollutants have on the
water use classifications. The Act requires EPA to develop
criteria for 126 priority toxic pollutants (that are the most
persistent, prevalent, and toxic of pollutants). States may
use EPA criteria or develop their own scientifically
defensible criteria.
§303(c)(2)(B) of the Act affords states the following three
scientifically and technically sound options (or some
combination thereof) for establishing criteria:
P adopt statewide numeric criteria for all §307(a) toxic
pollutants for which EPA has developed criteria
guidance, regardless of whether the pollutants are
known to be present;
P adopt specific numeric criteria for §307(a) toxic
pollutants as necessary to support designated uses
where such pollutants are discharged or are present
in the affected waters and could reasonably be
expected to interfere with designated uses; or
P adopt a "translator procedure" to be applied to a
narrative water quality standard provision that
prohibits toxicity in receiving waters.
In establishing and revising water quality standards, states
must review all available data to determine whether the
discharge or the presence of a toxic pollutant is impairing,
or is likely to impair, the attainment of the designated uses
of any waterbody. If data indicate that it is reasonable to
expect the toxic pollutant to impair the use, or it actually is
impairing the use, then the state must adopt a numeric limit
for the specific pollutant.
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In identifying the need for numeric criteria, states are
encouraged to use a variety of information and data such as:
P ambient water monitoring data, including those for
sediment and aquatic life (e.g., fish tissue data),
P National Pollutant Discharge Elimination System
(NPDES) permit applications and permittee self-
monitoring reports,
P effluent guideline development documents, many of
which contain §307(a)(l) priority pollutant scans,
P public water supply source monitoring data noting
pollutants with Maximum Contaminant Levels,
P information in annual reports from the Toxic
Chemical Release Inventor, and
P any other relevant information on toxic pollutants
collected by federal, state, interstate agencies,
academic groups, or scientific organizations.
Where any information and data review indicates a
reasonable expectation of a problem from the discharge or
presence of toxic pollutants, the state should identify the
pollutant(s) and the relevant waterbody segment(s). In
making these determinations, states should use their own
EPA approved criteria or existing EPA water quality
criteria. Upon completion of review, states may use other
means to establish final criteria for inclusion in their
standards.
States are required, at a minimum, to review their water
quality standards once every 3 years and obtain EPA
approval for the standards. If EPA disapproves a state's
water quality standards, the Act requires EPA to
promulgate new standards for the state. EPA may also
propose and promulgate a new and revised standard
applicable to one or more states if such a standard is
necessary to meet the requirements of the Act. This was the
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case in 1992, when EPA promulgated toxics criteria, under
the National Toxics Rule, for those states not complying
with the Act.
Antidegradation	40 CFR 131.12, Antidegradation policy, requires states to
Requirements	have an antidegradation policy to conserve, maintain, and
protect existing uses of waterbodies and maintain water
quality. The antidegradation policy also should require that
the state protect waters of exceptionally high quality or
value. The CFR also requires the state to identify the
methods of implementation. Chapter 4, Section 4.3 of
EPA's Water Quality Standards Handbook-Second Edition,
provides that antidegradation procedures specify how the
state will determine on a case-by-case basis whether, and to
what extent, water quality may be lowered.
Ambient Monitoring	40 CFR 130.4, Water Quality Monitoring, requires that
Requirements	states establish appropriate testing techniques to monitor
water quality. This monitoring information is to be used to
support activities to abate and control pollution, develop
water quality standards, and report water quality
information to the public. The regulation further requires
that water monitoring programs include the collection and
analysis of physical, chemical, and biological data, and
quality assurance and control programs to assure
scientifically valid data.
EPA's Section 106 and 604(b) Grant Guidance, dated
October 17, 1994, recommended that states provide a
multi-year monitoring strategy with their grant applications.
The monitoring strategy should address how the state will
assess all waters on a periodic basis using a monitoring
design targeted to the conditions of, and goals for, the
waters. The multi-year strategy was to provide the
framework for the regional/state annual work plan
negotiations. The guidance recommended that the state
address specific elements, including water quality problems,
information gaps, time lines, testing approaches,
coordination with other agencies, and quality assurance.
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States are required to conduct planning based on water
quality problems identified in their water quality
assessment reports. The requirements of 40 CFR 130.5,
Continuing planning process, provide that states establish a
process for managing their water quality program.
Additionally, the requirements of 40 CFR 130.6, Water
quality management plans, provides that states prepare
water quality management plans that identify and
recommend procedures to control priority point and non-
point water quality problems. The state's annual work
programs should be based on the water quality management
plans and water quality problems identified in the water
quality assessment reports.
Reporting Requirements	§305(b) of the Act requires each state to assess and report
to EPA every 2 years on the condition of its waters.
Reporting requirements are further described in EPA's
Guidelines for Preparation of the Comprehensive State
Water Quality Assessments [305(b) Reports] and
Electronic Updates, dated September 1997. The §305(b)
report is used as a report to Congress to meet the Act
requirements; to help states focus resources on priority
areas; and to provide useful and accessible data to decision
makers.
§3 03(d) of the Act requires each state to prepare a
prioritized list of impaired water bodies that do not fully
support their designated use. From this list, the state is
required to develop total maximum daily loads, which are
allocations of how much of a pollutant dischargers can
release into each water body and still meet the state's
water quality standards.
The Louisiana Department of Environmental Quality (the
Department) is responsible for protecting and maintaining
Louisiana's water quality. All changes to water quality
standards are developed within the Department and
certified by the Department's General Counsel. The
Department the State Department of Health and Hospitals
share the responsibility for the protection of primary contact
Louisiana Water Quality
Program
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recreation or "high use bathing waters." In fiscal 1999,
approximately $1.4 million of §106 grant funds were
awarded to the Department to support the water quality
activities discussed in this report and other various water
quality related activities within the State.
SCOPE AND	We performed our audit in accordance with the Government
METHODOLOGY	Auditing Standards (1994 revision) issued
by the Comptroller General of the United States as they
apply to program audits. Our review included tests of
the program records and other auditing procedures we
considered necessary. Our fieldwork was conducted from
April 1999 through June 2000, at Region 6 in Dallas, Texas,
and the Louisiana Department of Environmental Quality in
Baton Rouge, Louisiana. See Exhibit 1 for our scope and
detailed methodology.
PRIOR AUDIT	Neither OIG nor the U. S. General Accounting Office has
COVERAGE	issued any recent reports directly related to Louisiana's
water quality standards, monitoring, and reporting program.
Since 1998, OIG has completed similar audits of water
quality programs in eight states. See Exhibit 2 for a listing
of previous OIG water quality reports. Common issues
identified in the other reports include: water quality
standards; antidegradation polices and implementation
plans; fecal coliform and E. Coli in recreational waters;
triennial reviews and EPA approval of standards;
submission of required water quality planning
documents; and water quality monitoring and reporting.
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CHAPTER 2
REGION 6 OVERSIGHT OF LOUISIANA'S
MONITORING PROGRAM WAS LIMITED
Region 6 generally implemented effective procedures to
approve and evaluate Louisiana's water quality standards.
The Region's oversight of the State's monitoring program,
however, was limited because the Region had not made a
formal evaluation of the adequacy of the program relative to
the monitoring requirements of §106 and the reporting
requirements of §305(b). The Region's ability to evaluate
the program was limited by Louisiana's untimely and
incomplete water quality planning documents. Without a
formal evaluation of the program, the Region cannot be
assured that the requirements of the Act are being met or
whether the State has focused its water quality efforts on
priority areas.
EFFECTIVE OVERSIGHT Region 6 generally implemented effective procedures to
OF	approve Louisiana water quality standards and placed a high
WATER QUALITY	priority on the oversight of water quality standards
STANDARDS	development. As part of its oversight, Region 6 routinely
communicated with Louisiana personnel to discuss
problems and answer questions that came up during the
development of water quality criteria. This open
communication assisted in identifying problems at an early
stage and made the approval process quick with few
complications. Cooperation between Region 6 and
Louisiana throughout the water quality standards setting
process contributed to an effective water quality standards
setting process.
LIMITED OVERSIGHT	Region 6's oversight of the State's monitoring efforts were
OF MONITORING	limited because the Region had not made a formal
PROGRAM	evaluation of the adequacy of the program relative to
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the monitoring requirements of §106 and the reporting
requirements of §305(b). The Region's ability to evaluate
the program was limited by Louisiana's untimely and
incomplete water quality planning documents. As discussed
in Chapter 4 , Louisiana had not communicated significant
changes to its monitoring program through updated
planning documents as provided in the planning
requirements of 40 CFR 130.5. As a result, Region 6's
involvement in the State's monitoring program was limited.
The monitoring strategy is intended to serve as a planning
mechanism to ensure the adequacy of states' monitoring
programs and eligibility for continued grant funding under
§106 of the Act. Without updated information, Region 6
could not evaluate Louisiana's monitoring program and
determine if the requirements of the Act were being met.
CONCLUSION	Region 6's active involvement in Louisiana's standards
setting process contributed overall to an effective process.
Timely and complete water quality planning documents
should provide Region 6 with the opportunity to fulfill its
oversight responsibilities.
RECOMMENDATIONS	We recommend the Regional Administrator:
2-1. Negotiate firm §106 grant commitments with
Louisiana to ensure timely submittal of required
water quality planning documents, including the
Continuing Planning Process, Quality Assurance
Project Plan, and a State monitoring strategy.
2-2. Consider imposing a §106 grant condition for
withholding grant funds if the required documents
are not submitted as negotiated.
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AGENCY AND STATE
COMMENTS AND OIG
EVALUATION
Region 6 provided no specific comments to the findings and
recommendations in this chapter. Louisiana provided
comments indicating that they had worked very closely with
Region 6 in addressing TMDL program needs, including
monitoring and assessment. Further, Louisiana responded
that EPA was very much aware and supportive of its revised
water quality monitoring strategy. It is Louisiana's
understanding that the monitoring strategy was described in
other documents such as the §305(b) Report and the §106
grant workplan, and will be further described in a revised
Continuing Planning Process document.
Louisiana's comments are acknowledged, and we agree
that the monitoring strategy is generally discussed in the
§305(b) Report and the §106 grant workplan. However,
we do not believe these discussions satisfy the intent of
a "multi-year monitoring strategy" as recommended in
EPA's Section 106 and 604(b) Grant Guidance discussed in
Chapter 1.
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^^^^^n^Regortin^rogran^Woul^Bette^rotec^tat^Waters
CHAPTER 3
IMPROVEMENTS TO WATER QUALITY STANDARDS WOULD
ENSURE FURTHER PROTECTION OF STATE WATER QUALITY
Louisiana has developed water quality standards that are
generally protective of the State's water quality. Louisiana
was proactive in the development and adoption of water
quality criteria for pollutants, in the absence of EPA criteria,
to make certain its citizens were protected against
dangerous pollutants found in State waters. The standards
setting process, however, could be improved by:
P using more sensitive analytical test methods than
currently used to assess water quality needs,
P adopting EPA recommended E. coli and/or
enterococci bacteria criteria, and
P clarifying procedures in the State's antidegradation
implementation plan.
ADOPTING CRITERIA
IN THE ABSENCE OF
EPA CRITERIA
Louisiana proactively developed and adopted water quality
criteria for several priority and non-priority pollutants in
the absence of EPA criteria. Using a variety of sources,
such as fish tissue studies and documented fish kills,
Louisiana realized that these pollutants had the potential to
interfere with attainment of designated uses and responded
by developing and adopting new criteria. Louisiana's
adoption of these criteria help to protect both human health
and aquatic life use designations.
Examples of pollutants which Louisiana developed and
adopted criteria for include: Lindane (gamma BHC,
hexachlorocyclohexane), Silvex (2,4,5-trichlorophenoxy)
and 2,4-D (2,4-dichlorophenoxyacetic acid), and eight
other compounds.
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Lindane	Louisiana adopted more stringent human health criteria
for Lindane because it was detected in fish tissue and
believed to have the potential for detrimental impacts on
both human health and aquatic life. Lindane, a priority
pollutant, accumulates in fish tissue and is considered
"persistent" in the aquatic environment.
Silvex and 2,4-D	The adoption of Silvex and 2,4-D, both non-priority
pollutants, were prompted by detections in drinking water
and the concerns for the potential to impact aquatic life and
human health. Fish kills were also associated with the use
of these herbicides.
Other Compounds	Louisiana developed criteria for eight compounds detected
in the Mississippi River, including: Bromodichloromethane
and Dibromochloromethane, 1,3-Dichloropropene, and five
Chlorinated Phenols. Louisiana determined that these
compounds, resulting from spills and/or unpermitted
discharges, were potentially harmful to human health.
USING MORE	Louisiana used analytical test methods that may not be
SENSITIVE TEST	sensitive enough to adequately assess the State's water
METHODS IS NEEDED	quality needs and protect human health. Test methods
TO BETTER ASSESS	should measure toxic pollutants at levels required to
WATER QUALITY	determine the need for state water quality criteria, and
NEEDS	detect pollutants in wastewater discharges at or below
the lowest EPA or state water quality criteria. Generally,
test methods used in Louisiana were sensitive enough to
confidently measure toxic pollutants at these levels.
However, the test methods used were not always sensitive
enough to determine if certain pollutants identified in their
permits were present at low levels in discharges. As a
result, the need for state water quality criteria may go
unheeded, and the impairment of water quality due to toxic
pollutants may go undetected.
EPA and Louisiana used guidance researched and
developed by EPA Region 6 for establishing its test
methods and minimum quantification levels. The
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guidance established minimum levels of sensitivity
from which the Region could establish a legal base for
enforcement and a threshold for reporting. The guidance
further acknowledged that the these minimum levels may
not be the most sensitive analysis for some pollutants.
We reviewed the limitations for parameters for which EPA
had established water quality criteria (iQuality Criteria for
Water 1986, as Amended) in 10 permits. The purpose of
the review was to determine if 40 CFR 136 analytical
methods were required which were sensitive enough to
measure down to the lowest published EPA water quality
criteria level. Our review identified nine toxic pollutants (all
suspected carcinogens) where test methods were used that
were not sensitive enough to measure this concentration
level. The nine pollutants are listed in Exhibit 3. Permittee
self-monitoring (discharge monitoring report) data provided
to Louisiana only indicated that the pollutants were not
discharged at levels greater than the enforceable
quantification level. As a result, information was not
available to ascertain whether the State should have
established appropriate state water quality standards
and permit limitations for these parameters; rather,
only technology based limits were established.
Using EPA's permit writers guidance and EPA's published
water quality criteria document, in the absence of state
standards for these parameters, we calculated water quality
based requirements for the pollutants hexachloroethane
and benzo(b)floranthene in four permits. The requirements
calculated were more stringent than the technology
limitations established in the permit. In these instances,
more sensitive analytical methods should have been required
to determine if there was potential for the pollutants to be
discharged at a level which would result
in a water quality problem. If the potential for a toxic
problem was found, appropriate water quality standards
and permit limitations should have been established.
Without requiring measurements in NPDES discharges and
ambient waters down to the most stringent published EPA
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water quality criteria level, the State may not be able to
determine whether: the pollutants are present, water quality
based criteria are needed, or if designated uses are being
impaired.
ADOPTING E. COLI	Louisiana had not taken actions to adopt EPA recommended
AND/OR ENTEROCOCCI	E. coli and/or enterococci bacteria criteria. Although
CRITERIA WOULD MEET Region 6 had worked diligently with the State to adopt the
EPA REQUIREMENTS	criteria recommended in the Ambient Water Quality Criteria
for Bacteria - 1986, Louisiana had retained the use of fecal
coliform as its indicator organism for waterbodies with
primary contact recreation or "high use bathing waters" use
designations. To date, the two agencies responsible for
protecting high use bathing waters have been unable to
reach an agreement on an appropriate indicator organism.
On March 7, 1986, EPA published Ambient Water Quality
Criteria for Bacteria - 1986, which recommended E.coli
and/or enterococci as the indicator organisms, and addressed
fecal coliform as an inadequate indicator to provide
protection from swimming in bacteriologically contaminated
waters. In February 1998, EPA issued its Clean Water
Action Plan stating that the Agency would develop a
specific plan and schedule for the development of a new
generation of microbiological criteria. In March 1999, the
Office of Research and Development and the Office of
Water issued the Action Plan for Beaches and Recreational
Waters, advising states that EPA would promulgate the
Ambient Water Quality Criteria for Bacteria - 1986 bacteria
criteria by 2003 unless actions were taken by the states to
adopt the EPA recommended criteria, or scientifically
defensible alternatives.
Elevated bacteria levels can be hazardous to people
using water for recreational activities. EPA's current
recommended water quality criteria for bacteria are for the
protection from gastrointestinal illness; however, pathogens
can also cause illnesses ranging from sore throats to
meningitis and encephalitis. Given the potential for these
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illnesses, it would be in the best interest of the public if
Louisiana initiated actions to adopt the appropriate criteria
prior to EPA's proposed promulgation in 2003.
CLARIFYING	Although Louisiana has established an antidegradation
PROCEDURES WOULD	policy that meets the requirements of 40 CFR 131.12, the
STRENGTHEN	State could strengthen its antidegradation implementation
ANTIDEGRADATION	plan with further clarification of its procedures. The
IMPLEMENTATION	implementation plan does not contain specific details on
PLAN	the process the State will use to approve actions that may
impact water quality. Without specific implementation
procedures, Louisiana cannot determine how, on a case-by-
case basis whether, and to what extent, water quality may be
lowered.
Although states must follow the antidegradation policy
requirements of 40 CFR 131.12, EPA has not provided
national guidance to assist states in the development of
their implementation plans. In the absence of national
guidance, Region 6 proposed the use of Region 8
guidance to assist Louisiana in the development of their
implementation plan.
Louisiana's implementation plan contains basic information
on how the State will implement its antidegradation policy;
however, the plan does not contain specific details on the
processes the State will use to approve actions that may
impact water quality. To ensure consistency of policy
implementation and the protection of high quality waters,
Louisiana should consider providing further clarification of
its plan, including the:
P identification of specific activities being reviewed;
P identification of the sequence of steps in the
review process;
P differentiation between procedures used for
Outstanding Natural Resource Waters, high
quality waters, and all others; and
P utilization of more detail on documentation, public
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review, and intergovernmental coordination efforts.
CONCLUSION	Louisiana has developed water quality standards that
should protect public health and the environment by
supporting safe drinking water sources, fish consumption,
safe recreation, and healthy aquatic life use designations.
The use of more sensitive test methods, the adoption
of EPA's water quality criteria for bacteria, and the
clarification of the antidegradation implementation plan
will help Louisiana ensure further protection of the State's
water quality.
RECOMMENDATIONS	We recommend the Regional Administrator:
3-1. Consult with the Office of Water regarding the
development of new, or clarification to, existing
policies and/or regulations that would require
permittees to use the most sensitive 40 CFR 136
test methods to determine the existence, in point
source discharges and ambient waters, of toxic
pollutants for which the State or EPA has published
final criteria.
3-2. Continue efforts to encourage Louisiana to initiate
actions to adopt E.coli and/or enterococci criteria
prior to EPA's proposed promulgation in 2003.
3-3. Consult with the Office of Water regarding
the development of national guidance on
antidegradation implementation plans.
3-4. Assist Louisiana in providing further clarification
of its antidegradation implementation plan.
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AGENCY AND STATE
COMMENTS AND OIG
EVALUATION
Region 6 and Louisiana provided comments to clarify
portions of the chapter. We have incorporated the
comments and modified the chapter as appropriate.
Using More Sensitive
Analytical Test Methods
Region 6 generally agreed that the use of more sensitive test
methods could be more protective of state and EPA water
quality standards. However, Region 6 also agrees with
Louisiana that implementation of more sensitive test
methods would result in substantially increased costs to
permittees. Louisiana questioned whether higher costs of
more sensitive methods would provide additional
environmental benefit. Louisiana also raised other valid
concerns about the technical feasibility of using the more
sensitive tests. Both Region 6 and Louisiana have
expressed a willingness to use more sensitive test methods
where water quality problems have already been identified.
Based on the concerns raised by both Region 6 and
Louisiana, the Region should consult with EPA's Office
of Water over the need for additional Agency policy that
addresses this issue. It is our opinion that Agency policy
is needed to address various implementation issues including
the selection of the most appropriate test method, cost
benefit analyses supporting use of more sensitive test
methods, resolution of various technical issues raised by the
states, and the need for new or alternative test methods.
Adopting E. coli and/or
Enterococci
Region 6 generally agreed with our recommendation and
noted that they are working diligently with Louisiana on the
matter. Region 6 noted further that there is one triennial
review remaining in which Louisiana may adopt the EPA
recommended criteria, or scientifically defensible
alternatives, before EPA will promulgate criteria in 2003.
Louisiana's response highlighted the complexity in changing
indicator organisms, the problems in coordinating their
efforts with the Department of Health and Hospitals
regulations, and their need to progress in a determined
manner to ensure they make the correct decision. Louisiana
indicated that they would continue current studies seeking a
solution.
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OIG commends Region 6 and Louisiana for their current
effort in addressing the matter. It is our opinion that it
would be in the best interest of Louisiana to continue
actions toward establishing an approved indicator organism
that more appropriately addresses State needs.
Clarifying Antidegradation	Region 6 provided no specific comments to this issue.
Implementation Procedures	Louisiana generally disagreed with the issue and provided
that the established antidegradation policy meets the
requirements of 40 CFR 131.12. The antidegradation
policy, along with the implementation plan, had been
approved by Region 6. Louisiana further provided that
procedures that serve to implement the antidegradation
policy are integrated into all water quality related activities
within the Department and, as such, serve to accomplish
the intent of an antidegradation review. The response
included a discussion of each of the items identified for
clarification. Louisiana expressed an overall concern that a
recommendation is being made to document a process for
which there is no Region 6 or national guidance.
Louisiana's comments are acknowledged and we agree, as
stated in the report, that the antidegradation policy meets
the requirements of 40 CFR 131.12. The report has been
modified to reflect four items that we believe need
clarification in order to ensure consistency of policy
implementation and the protection of high quality waters.
Regarding the absence of national guidance, it is our
understanding that Region 6 has previously proposed the
use of Region 8 guidance to assist states in the development
of implementation plans. We support Region 6's use of the
Region 8 guidance, pending the issuance of national
guidance. An additional recommendation, directed at the
Office of Water and the development of national
implementation plan guidance, has been included in the
report.
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^^^^^n^Regortin^rogran^Woul^Bette^rotec^tat^Waters
CHAPTER 4
WATER QUALITY MONITORING AND ASSESSMENT
PROGRAM COULD BE IMPROVED
Louisiana generally implemented procedures to effectively
monitor and assess the quality of State waters. The water
quality reports issued by Louisiana of its monitoring and
assessment activities were submitted to Region 6 as
required. The program, however, could be improved with
the use of biological monitoring, and updated and complete
water quality planning documents. Without the use of
biological monitoring, Louisiana cannot ensure that its
water quality standards are protective of all designated uses.
Without timely and complete planning documents, the State
may not be focusing its water quality efforts on priority
areas.
BIOLOGICAL	The overall usefulness and accuracy of the Louisiana
MONITORING WOULD	monitoring and assessment program would be enhanced
ENHANCE PROGRAM	with the collection and analysis of biological data.
Louisiana's water quality assessments were conducted
primarily using chemical-specific data obtained from the
State's ambient monitoring network. Although Region 6
has encouraged Louisiana to implement a biological
monitoring program, the State does not believe that
widespread ambient biological monitoring is an effective or
defensible way to assess designated uses. Louisiana has
expressed to Region 6 that it does not intend to initiate a
costly and intensive biological monitoring program that
does not help accurately assess waterbodies. Louisiana,
however, will continue to use biological monitoring in
conjunction with use attainability analyses, fish consumption
investigations, ecoregion program surveys, fish kill
investigations, and other special studies and surveys.
Additional monitoring data would provide Louisiana with a
better basis for determining the effectiveness of its water
management program and help in determining the actual
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condition of the State's waters. Chemical-specific testing
alone does not provide the necessary information to assess
the biological condition of the water. Emphasis only on
chemical testing could result in Louisiana not identifying
impaired waters.
EPA strongly recommends using an integrated assessment
process involving biological, habitat, physical/chemical, and
toxicity monitoring. Biological indicators are beneficial in
revealing whether an ecosystem is functioning properly and
is self-sustaining. Specifically, biological
data provide a good measure of what has happened in a
waterbody, whereas chemical and toxicity data are a better
measure of what could happen in a waterbody.
WATER QUALITY
PLANNING
DOCUMENTS NOT
UPDATED OR
COMPLETE
Louisiana did not update its water quality planning
documents to reflect significant changes to its monitoring
strategy, as required by 40 CFR 130.5. Additionally,
the State's Surface Water Monitoring Program Quality
Assurance Project Plan includes sections that do not meet
applicable EPA requirements. Without updated and
appropriate planning documents, the potential exists that the
State may not be focusing its water quality efforts on
priority areas.
Continuing Planning Process
Louisiana had not updated its Continuing Planning Process
to reflect revisions to its monitoring program, as required by
40 CFR 130.5. In 1998, the State's monitoring program
was revised from that of a traditional fixed station approach
to the EPA recommended rotating basin approach.
Louisiana, however, had not documented the change as part
of its continuing planning process and had not submitted it
to Region 6 for review and approval.
The continuing planning process should include a strategy
that describes how the monitoring program design will meet
the informational requirements of §305(b), over a specified
period of time, with either a comprehensive assessment of
all waters or a representative selection of
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waters. The proposed design should be consistent with the
methodology in the most recent §305(b) reporting guidance
for comprehensive assessments and EPA's quality assurance
requirements and guidance.
Quality Assurance	Louisiana's quality assurance project plan was not updated
Project Plan	timely and includes sections that do not meet applicable
EPA requirements. Similar to the continuing planning
process, Louisiana had not updated its quality assurance
plan since 1994 to reflect changes made in 1998 to its
monitoring strategy. It was not until September 16, 1999,
that Louisiana submitted its revised quality assurance plan
to EPA, incorporating the changes.
The revised plan as submitted, however, included sections
that do not meet applicable EPA requirements. Without an
adequate quality assurance plan, the integrity of the State's
monitoring and overall water quality program may be
jeopardized.
In a memorandum to Louisiana, dated February 8, 2000,
Region 6 noted that some sections of the quality assurance
project plan were excellent; however, other sections did not
meet applicable EPA requirements delineated in EPA Order
5360.1, and EPA QA/R5. The Region 6 technical review
identified issues that must be resolved for the plan to be
technically approved. In general, Region 6 noted that while
there was a considerable amount of useful information in the
plan, the study design portion of the plan does not provide
sufficient information regarding connections between the
stated objectives, sample collection activities, and data
assessment. Both short-term and long-term corrective
actions were proposed by the Region in its review.
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WATER QUALITY	Louisiana submitted to EPA the required 1998 Water
REPORTS SUBMITTED	Quality Inventory Report (305(b)) and the Water Quality
AS REQUIRED	Limited Waterbodies -303(d) List.
§305(b) of the Act requires each state to assess and report
to EPA every 2 years on the condition of its waters. The
§305(b) report is used as a report to Congress to meet the
Act requirements, to help states focus resources on priority
areas, and to provide useful and accessible data to decision
makers. §3 03(d) of the Act requires each state to prepare a
prioritized list of impaired water bodies that do not fully
support their designated use.
Louisiana consistently applied appropriate methods and
procedures in performing its river and stream water quality
assessments for the 1998 reporting period. Our review,
which included 18 judgementally selected waterbodies,
disclosed no significant discrepancies or inconsistencies with
the assessment process.
Louisiana's water quality assessments were conducted
primarily from data obtained from the ambient monitoring
network. Additionally, other data resulting from special
studies and investigations, and water quality data from other
agencies was used in the assessment process. To determine
the support or non-support of designated uses, Louisiana
compared monitoring data with specific water quality
criteria protective of those uses. The criteria used was
taken from the State's water quality standards.
The assessments were appropriately presented in the State's
1998 §305(b) report. Louisiana's §303(d) list, which is
generated from the §305(b) report, was approved by EPA
on September 14, 1998.1
l The 1998 §303(d) list was subject to a lawsuit styled Sierra Club et al. v. Clifford et al.. No. 96-0527 (E.D. La),
which is currently on appeal in the United States Court of Appeals for the Fifth Circuit. The 1998 §303(d) list has
been subsequently modified a number of times in accordance with that lawsuit.
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CONCLUSION	The use of biological monitoring would provide Louisiana
with a better basis for determining the effectiveness of its
water quality management program. Also, updated and
appropriate planning documents would help ensure that
Louisiana is focusing its water quality efforts in priority
areas.
RECOMMENDATIONS	We recommend the Regional Administrator assist Louisiana
in:
4-1.	Formulating a long range plan to expand its
monitoring program to include biological
monitoring that will meet EPA requirements.
4-2.	Developing and updating required water quality
planning documents, including the Continuing
Planning Process, Quality Assurance Project
Plan, and a State monitoring strategy.
AGENCY AND STATE
COMMENTS AND OIG
EVALUATION
Region 6 and the State provided comments to clarify
portions of the chapter. We have incorporated these
comments and modified the chapter as appropriate.
Biological Monitoring
Region 6 agrees with the recommendations and further
provides that Louisiana's standards program should also
include the development and adoption of numeric biological
criteria for wadeable streams in regions that lie north of the
coastal plains. According to Region 6, Louisiana has
completed the process of stream classification and
conducted multiple years of reference stream sampling to
characterize fish and macroinvertebrate communities in
these regions. Louisiana has also developed preliminary
biological criteria based on these results. The next step for
Louisiana would be the adoption of biological criteria into
the State standards.
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Louisiana generally did not agree with the recommendation.
Although Louisiana acknowledges that biological
monitoring would be a benefit to water quality assessment,
they contend the State's water quality is protected by the
State's standards because the standards: (1) were designed
to be protective of all designated uses, (2) are continuously
revised as needed to improve upon that protection, (3) have
been publicly noticed and approved for publication as
Louisiana regulation, and (4) have been approved by EPA.
Louisiana expressed concern with the lack of clear guidance
or regulation concerning the proper combined
use of physical, chemical and biological monitoring.
Louisiana also expressed a concern related to problems
throughout the State with dissolved oxygen levels. Many if
not most Louisiana water bodies support fish and vertebrate
populations that are both diverse and abundant, despite the
fact that dissolved oxygen does not meet the EPA approved
standard. Louisiana questions the use of biological
monitoring in this instance.
We acknowledge Louisiana's comments and recognize
the difficulties and challenges the State faces in
implementing a biological monitoring program. We
continue to maintain, however, that biological monitoring
would enhance the overall usefulness and accuracy of the
State's monitoring and assessment program.
Water Quality Planning	Region 6 requested clarification on several points related to
Documents	the finding and recommendation for this issue. Louisiana's
comments focused on the reference to EPA's §305(b)
reporting and quality assurance guidance in preparing a
monitoring strategy. Louisiana emphasized that EPA
cannot impose its will on the states based on guidance and
states are not required to follow EPA guidance.
Louisiana's comments are acknowledged; however, the
regulations for State and Local Assistance (40 CFR 35.141)
include a provision for approval that proposed outputs,
under continuing program grants, be consistent with EPA
guidance. Furthermore, EPA guidance, as it applies to
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Water Quality Assessment
and Reporting Requirements
water quality, is developed to assist states with the
implementation of provisions described in the Act and
the water quality standards regulations (40 CFR Part 131).
When a state decides to use an approach different from the
one which EPA recommends, its reasoning should be based
on EPA guidance methodology, and/or other sound
scientific processes.
Based on comments from both Region 6 and Louisiana, we
have modified the report to include issues regarding the
305(b) Report and the 303(d) list. Because the report
contained no recommendation and required no actions on
the part of Region 6 or Louisiana, we did not consider it
necessary to solicit additional comments.
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EXHIBIT 1
SCOPE AND METHODOLOGY
We reviewed Louisiana's internal controls over water quality standards setting, monitoring, and
reporting. We analyzed internal controls to assure compliance with federal statutory and
regulatory criteria and with Louisiana policies and procedures. Our audit disclosed areas needing
improvement and areas of commendation for both Louisiana and Region 6, which are discussed in
Chapters 2 through 4.
To determine Louisiana's processes for establishing water quality standards, we interviewed
Louisiana's Department of Environmental Quality staff and documented their processes for
developing and adopting water quality standards. We reviewed Louisiana's water quality
standards activities from 1994 through the November 1998 triennial review as adopted in
Louisiana environmental law Title 33, Environmental Quality, Part IX Water Quality
Regulations, Chapter 11, Surface Water Quality Standards. We reviewed policy and guidance
papers to determine if established water quality standards were in compliance with the Clean
Water Act and applicable federal regulations.
In reviewing the program, we interviewed Louisiana Department of Environmental Quality
staff and documented their process for monitoring and assessing water quality data. We also
documented processes for preparing and reporting on the water quality assessment report and
the impaired waterbody list. We reviewed Louisiana's 1998 303(d) list and the 305(b) report
and assessed whether the reports for reporting water quality were consistent with federal
regulations and EPA guidance.
We judgementally selected 18 waterbodies to test and evaluate the processes for setting use
classifications, establishing water criteria, monitoring and assessing waterbodies, recording
monitoring data in STORET, and reporting on water quality. The sample, which included a mix of
both impaired and supporting waters, included a waterbody from each of the twelve basins.
We reviewed NPDES permits for ten major facilities in Louisiana. We reviewed the permits to
determine if they included permitted discharges of pollutants for which Louisiana did not have
water quality standards. Other than for the purpose stated, we did not perform nor did we intend
to perform a review of Louisiana's permitting process or of Louisiana's permit backlog.
To determine if Region 6 implemented effective procedures to approve water quality standards
and evaluate Louisiana's water quality standards setting, monitoring, and reporting program, we
interviewed Region 6 officials to determine how they ensured compliance with the Act and
applicable federal regulations. We identified Region 6's processes for reviewing the State's water
quality standards, water quality inventory report, and the impaired waterbodies list.
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EXHIBIT 2
PREVIOUS OIG WATER QUALITY REPORTS
1.	Missouri's Water Quality Standards and Monitoring
E1HWF7-07-0023-8100080, March 31, 1998
2.	Colorado Water Quality Standards, Monitoring and Reporting Program
E1HWF8-07-0004-9100093, March 10, 1999
3.	Oregon's Water Quality Program
E1HWF8-10-0024-9100119, March 31, 1999
4.	Region III Water Quality Standards, Monitoring, and Reporting
E1HWF7-03-0160, March 31, 1999
5.	Ohio's Water Quality Program
99P00210, June 30, 1999
6.	New Jersey's Water Quality Monitoring Program
1998-1-00225,	July 21, 1999
7.	Arkansas Water Quality Standards, Monitoring, and Reporting Program
1999-R6-0001321-100245,	August 19, 1999
8.	Mississippi's Water Quality Standards, Monitoring and Reporting
1999-P00219, September 29, 1999
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EXHIBIT 3
POLLUTANTS REQUIRING THE USE OF MORE
SENSITIVE TEST METHODS
No.
Pollutant
1
Acrylonitrile
2
Benzo(a)anthracene
3
Benzo(b)fluoranthere
4
Benzo(k)fluoranthene
5
BIS-2 Ethylhexyl Phthalate
6
Chrysene
7
2,4 Dinitrotoluene
8
Hexachloroethane
9
N-Nitrosodimethyla-mine
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APPENDIX I
AGENCY RESPONSE
September 18, 2000
MEMORANDUM
SUBJECT: Response to Draft Report of Audit No. 1999-0000185
Improvements to Louisiana's Water Quality Program
FROM: Lynda F. Carroll
Assistant Regional Administrator
for Management (6MD)
TO:	Randy P. Holthaus
Audit Manager
Dallas Office of Inspector General
Attached is our response to the draft report on Louisiana's's water quality standards,
monitoring, and reporting program. After reviewing the report, consulting with your staff and
addressing our concerns, it is our understanding that Chapter 4 of your draft will be dropped.
Therefore, no comments are provided on this portion of the draft audit report. General comments
and comment on the remaining chapters are attached.
We will look forward to receiving your revised draft report at which time we will indicate our
concurrence or non-concurrence with each finding.
Thank you for the opportunity to provided comments. If you have any questions, regarding
these comments, please feel free to give me a call or have your staff contact Diane Taheri,
Regional Audit Resolution Coordinator at x7460.
Attachment
cc: Louisiana Department of Environmental Quality
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APPENDIX I
Page 2 of 4
WATER QUALITY PROTECTION DIVISION
Comments on OIG Draft Report of Louisiana's Water Quality Standards
GENERAL COMMENTS
There are some concerns that the title may be inappropriate considering that the water program is
comprised of several other programs that are not addressed in this report. We recommend replacing
water quality program with water quality standards, monitoring, and reporting program.
CHAPTER 1
Background, Criteria Requirements, page 3
The establishment and revision of water quality standards is discussed in the second paragraph in
addition to suggestions for assisting with identifying the need for numeric criteria. This discussion
would be more accurate if the section beginning with "In identifying the need for numeric criteria..."
were replaced with all available options for establishing criteria.
Section 131.11(b) of the water quality standards regulations provides states the option to establish
criteria by (1) adopting criteria published by EPA under §304(a) of the Act; (2) modifying §304(a)
guidance to reflect site-specific conditions; (3) use other scientifically defensible methods; or (4)
establish narrative criteria or criteria based on biomonitoring methods where appropriate numerical
criteria cannot be established.
CHAPTER 2
Sensitive Test Methods, page 8
EPA Region 6 understands the expressed concern of the OIG Report as it relates to testing
methodology for effluent discharge monitoring. While Region 6 agrees that the blanket use of the
most sensitive test methods could be more protective of state and EPA water quality standards, such
testing would result in very substantial increases in monitoring costs for municipal and industrial
facilities. We agree that the decision to develop policy or regulations requiring the use of the most
sensitive test methods would need to be addressed on a national basis. Region 6 agrees to consult
with the EPA Office of Water on requiring such methods. We will also continue to encourage the
State to use more sensitive analytical test methods for specific chemicals in cases where the water
body is listed as impaired or threatened for such chemicals, or where there is specific information to
support such analytical methods.
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APPENDIX I
Page 3 of 4
E. coli and Enterococci Criteria, page 10
In this section, the upcoming promulgation of water quality criteria for bacteria should be
addressed properly. Reference is made to the federal register notice that published EPA's
recommended bacteria criteria. We suggest adding the title of the criteria document, Ambient Water
Quality Criteria for Bacteria - 1986, in addition to the following statements. The Office of Research
and Development and the Office of Water issued the Action Plan for Beaches and Recreational
Waters (EPA/600/R-98/079, March 1999) advising the states that EPA would promulgate the Ambient
Water Quality Criteria for Bacteria - 1986 by 2003, unless actions were taken by the states to adopt
the EPA recommended criteria, or scientifically defensible alternatives. The transition to E. coli and/or
enterococci indicators are also a priority for the triennial reviews of water quality standards that will
occur in FY 2000-2002.
The OIG recommends that the Regional Administrator "encourage Louisiana... to adopt
E. coli and/or enterococci criteria" prior to the anticipated promulgation in 2003. EPA Region 6 has
worked diligently with the State on this very matter. Most recently a meeting was held on
August 30, 2000, with representatives from the Louisiana Department of Environmental Quality, the
Louisiana Department of Health and Hospitals, the U.S. Geological Survey (Baton Rouge office), and
EPA Region 6. Current studies, monitoring, data collection, and test methods were discussed, in
addition to EPA's recent DRAFT Implementation Guidance for Ambient Water Quality Criteria for
Bacteria - 1986 (EPA-823-D-00-001).
CHAPTER 3
Biological Monitoring, page 13
EPA disagrees with the statement that "biological monitoring is costly and more resource
intensive..." than water chemistry monitoring (page 14). Cost comparisons have shown that biological
monitoring is often less costly than either water chemistry monitoring or toxicity testing (Karr and Chu
1999, Yoder and Rankin 1995). It is inappropriate to compare the cost of a single water chemistry
sample to the cost of a single biological sample. Water chemistry monitoring requires multiple
repeated sampling events over time to adequately characterize water quality (Sanders et al. 1983). On
the contrary, biological monitoring integrates conditions over time and may be conducted with
effective results, under stable low flow conditions, once or twice per year (Mount 1994).
Recommendations for the standards program should include the completion of development and
adoption of numeric biological criteria for wadable streams in regions that lie north of the coastal
plains. LDEQ has completed the process of stream classification and conducted multiple years of
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APPENDIX I
Page 4 of 4
reference stream sampling to characterize fish and macroinvertebrate communities in these regions.
The LDEQ also developed preliminary biological criteria, based on these results. The next step is the
adoption of biological criteria into standards.
CHAPTER 5
Timely Submittal of Water Quality Planning Documents, page 19
This section discusses water quality planning documents in general with one reference to Chapter
3. Since there are a number of water quality planning documents that relate to the activities discussed
in Chapter 5, we would recommend that the report specify which planning documents are referenced
here to avoid confusion.
It is not clear in this chapter as to which grant requirements the OIG believes are not being met
that may make it necessary to withhold grant funds. Additionally, since most reporting requirements
are negotiated in work plans, we would prefer to have the recommendation ask for Section 106 grant
commitments rather than conditions. If the OIG recommends that EPA withhold grant funds, a
rationale to support this recommendation should be discussed within the report.
REFERENCES
Karr, J.R. and E.W. Chu. 1999. Restoring Life in Running Waters: Better Biological Monitoring.
Island Press. Washington, D.C.
Mount, D. 1994. A Comparison of Strengths and Limitations of Chemical Specific Criteria, Whole
Effluent Toxicity Testing, and Biosurveys. Prepared for Science Applications International
Corporation. Submitted to Environmental Protection Agency Office of Wastewater
Enforcement and Compliance. Washington, D.C.
Sanders, T.G., R.C. Ward, J.C. Loftis, T.D. Steele, D.D. Adrian, and V. Yevjevich. 1986. Design of
Networks for Monitoring Water Quality. Water Resources Publications. Highlands Ranch,
CO.
Yoder, C.O. and E.T. Rankin. 1995. Biological Criteria Program Development and
Implementation in Ohio in Davis, W.S. and T.P. Simon. Biological Assessment and Criteria:
Tools for Water Resource Planning and Decision-Making. Lewis Publishers. Boca Raton, FL.
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Improvements to Louisiana's Water Quality Standards, Monitoring
	and Reporting Program Would Better Protect State Waters
APPENDIX II
ABBREVIATIONS
Act
Clean Water Act
CFR
Code of Federal Regulations
EPA
Environmental Protection Agency
NPDES
National Pollutant Discharge Elimination System
OIG
Office of Inspector General
303(d) List
Impaired Water Body List
305(b) Report
Water Quality Assessment Report
the Department
Louisiana Department of Environmental Quality
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Improvements to Louisiana's Water Quality Standards, Monitoring
	and Reporting Program Would Better Protect State Waters
APPENDIX III
DISTRIBUTION
Office of Inspector General
Inspector General (2410)
Deputy Assistant Inspector General for Internal Audits (2421)
Headquarters Audit Liaison (2421)
Divisional Inspectors General for Audit
EPA Headquarters Office
Assistant Administrator for Water (4101)
Agency Followup Official (2710)
Agency Followup Coordinator (3304)
Associate Administrator for Regional Operations and State/Local Relations (1501)
Associate Administrator for Congressional and Intergovernmental Relations (1301)
Associate Administrator for Communications, Education, and Public Affairs (1701)
EPA Region 6
Director, Water Quality Protection Division (6WQ)
Director, Office of External Affairs (6XA)
Audit Followup Coordinator (6MD-R)
Regional Library
Regional Offices
Regional Administrators
Louisiana Department of Environmental Quality
Secretary
Chief, Planning and Assessment Section
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