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U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF INSPECTOR GENERAL
Ensuring clean and safe water
EPA Helps States Reduce
Trash, Including Plastic, in
U.S. Waterways but Needs to
Identify Obstacles and Develop
Strategies for Further Progress
Report No. 21-P-0130
May 11, 2021

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Report Contributors:	Kathlene Butler
Morgan Collier
Lauretta Joseph
Jayne Lilienfeld-Jones
Tim Roach
Nirvair Stein
Abbreviations
CWA	Clean Water Act
EPA	U.S. Environmental Protection Agency
MS4	Municipal Separate Storm Sewer System
NPDES	National Pollutant Discharge Elimination System
OIG	Office of Inspector General
TMDL	Total Maximum Daily Load
Cover Photo: Improperly disposed trash can end up in waterways and flow downstream into
the oceans, where it becomes marine debris. (EPA photo)
Are you aware of fraud, waste, or abuse in an
EPA program?
EPA Inspector General Hotline
1200 Pennsylvania Avenue, NW (2431T)
Washington, D.C. 20460
(888) 546-8740
(202) 566-2599 (fax)
OIG Hotline@epa.gov
Learn more about our OIG Hotline.
EPA Office of Inspector General
1200 Pennsylvania Avenue, NW (2410T)
Washington, D.C. 20460
(202) 566-2391
www.epa.gov/oiq
Subscribe to our Email Updates
Follow us on Twitter @EPAoig
Send us your Project Suggestions

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Office of Inspector General
May 11, 2021
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At a Glance
Why We Did This Audit
We conducted this audit to
identify the extent to which the
U.S. Environmental Protection
Agency's existing Clean Water
Act programs and Office of
Research and Development
initiatives address threats and
risks to public health and the
environment from trash,
including plastic, within the
waters of the United States.
This report focuses on our audit
findings related to the Office of
Water's Clean Water Act
programs. We issued Report
No. 21-N-0052 on January 6,
2021, to summarize our audit
findings related to the Office of
Research and Development's
initiatives.
Improperly handled trash,
which includes plastic, can
enter fresh water and marine
ecosystems, thereby posing
risks to human health and the
environment.
This audit addresses the
following:
•	Ensuring clean and safe
water.
This audit addresses a key EPA
management challenge:
•	Overseeing states
implementing EPA programs.
Address inquiries to our public
affairs office at (202) 566-2391 or
OIG WEBCOMMENTS@epa.gov.
List of OIG reports.
EPA Helps States Reduce Trash, Including Plastic,
in U.S. Waterways but Needs to Identify Obstacles
and Develop Strategies for Further Progress
What We Found
The EPA and states have not widely applied
all the tools established by the Clean Water
Act to reduce the trash, including plastic, in
U.S. waterways. Trash pollution in water
bodies is challenging to control because:
The EPA and states can
reduce the volume of trash,
including plastics, in
U.S. waterways by evaluating
barriers to implementing the
Clean Water Act and
developing strategies to
overcome those barriers.
•	It is made up of many substances.
•	It is both a point- and nonpoint-source
pollutant.
•	The EPA has not established consistent methods for measuring it.
Despite these challenges, thousands of municipalities across the United States
control stormwater discharges of trash through the Clean Water Act's National
Pollutant Discharge Elimination System program, specifically through permits for
municipal separate storm sewer systems. In addition, the EPA, states, and
municipalities implement a variety of nonregulatory initiatives to prevent and
remove trash from waterways.
The EPA can further improve its efforts to reduce trash, including plastic, in U.S.
waterways by evaluating the regulatory and nonregulatory obstacles facing states
and municipalities and by continuing its support of trash-reduction initiatives.
Recommendations and Planned Agency Corrective Actions
We make three recommendations to the assistant administrator for Water:
•	Evaluate the obstacles to implementing the Clean Water Act to control trash
in U.S. waterways and provide a public report describing those obstacles.
•	Develop and disseminate strategies to states and municipalities for
addressing the obstacles identified in the evaluation.
•	Support state and local municipalities' efforts to control trash through
National Pollutant Discharge Elimination System permits for municipal
separate sewer systems by publishing guidance documents such as the
Trash Stormwater Permit Compendium and the U.S. EPA Escaped Trash
Assessment Protocol.
The EPA agreed with our recommendations and proposed acceptable corrective
actions and estimated completed dates. Recommendations 1 and 2 are resolved
with corrective actions pending, and Recommendation 3 is completed.

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
THE INSPECTOR GENERAL
May 11, 2021
MEMORANDUM
SUBJECT: EPA Helps States Reduce Trash, Including Plastic, in U.S. Waterways but Needs to
Identify Obstacles and Develop Strategies for Further Progress
Report No. 21-P-0130
This is our report on the subject audit conducted by the Office of Inspector General of the
U.S. Environmental Protection Agency. The project number for this audit was OA&E-FY19-0086. This
report contains findings that describe the problems the OIG has identified and corrective actions the OIG
recommends. Final determinations on matters in this report will be made by EPA managers in accordance
with established audit resolution procedures.
The Office of Water is responsible for the issues discussed in this report.
We issued three recommendations in this report. In accordance with EPA Manual 2750, your office
completed corrective actions for Recommendation 3. Your office also provided acceptable planned
corrective actions and estimated milestone dates in response to Recommendations 1 and 2. In accordance
with EPA Manual 2750, all recommendations are either completed or resolved with corrective actions
pending, and no further response is required. However, if you submit a response, it will be posted on the
OIG's website, along with our memorandum commenting on your response. Your response should be
provided as an Adobe PDF file that complies with the accessibility requirements of Section 508 of the
Rehabilitation Act of 1973, as amended. The final response should not contain data that you do not want
to be released to the public; if your response contains such data, you should identify the data for redaction
or removal along with corresponding justification.
FROM: Sean W. O'Donnell
TO:
Radhika Fox, Acting Assistant Administrator
Office of Water
We will post this report to our website at www.epa.gov/oig.

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EPA Helps States Reduce Trash, Including Plastic,
in U.S. Waterways but Needs to Identify Obstacles
and Develop Strategies for Further Progress
21-P-0130
Table of C
Purpose		1
Background		1
Responsible Offices		3
Scope and Methodology		3
Prior Report		4
Results		4
States Face Obstacles to Establish Measurable Criteria to Achieve
Water Quality Standards Addressing Trash Pollution		5
Even When States List Trash as an Impairment, Few Establish TMDLs		6
NPDES Permits for MS4s Incorporate Trash Control Requirements,
but Some States Request Additional Assistance		7
EPA Programs and Activities Help Reduce Trash in Waterways		7
Conclusions		8
Recommendations		9
Agency Response and OIG Assessment		9
Status of Recommendations and Potential Monetary Benefits		10
Appendices
A Internal Control Assessment		11
B Agency Response to Draft Report		12
C Agency Revisions to Proposed Corrective Actions		15
D Distribution		17

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Purpose
The U.S. Environmental Protection Agency's Office of Inspector General
conducted an audit to identify the extent to which the EPA's existing Clean Water
Act programs and Office of Research and Development initiatives address threats
and risks to public health and the environment
from plastic pollution within the waters of the
United States. This report focuses on our audit
findings related to the Office of Water's CWA
programs, which address plastic pollution
through their focus on reducing trash in
waterways. We previously issued Report
No. 21-N-0052. Office of Research and
Development Initiatives to Address Threats
and Risks to Public Health and the Environment fi'om Plastic Pollution Within the
Waters of the United States, on January 6, 2021, to summarize our findings
related to the Office of Research and Development's initiatives for this audit.
Background
Improperly handled trash, which includes plastic, can enter fresh water and
marine ecosystems and pose risks to human health and the environment. Trash
pollution can prevent water bodies from attaining their designated uses, such as
the protection and propagation of fish and wildlife, recreation, or the protection of
public water supplies.
The CWA is the primary federal law governing the protection of the nation's
waters and establishes the basic structure for regulating discharges of pollutants.
Although trash is not specifically included in the definition of "pollutant" under
the CWA, the definition does include "garbage," "solid waste," and "industrial,
municipal, and agricultural waste," thereby encompassing trash and its
components. Trash consists of diverse materials, from plastic and food waste to
used tires and construction debris. It also comes from a variety of sources, from
illegal dumping to stormwater runoff, making it challenging to monitor and assess.
With oversight from the EPA, states can apply the tools of the CWA to protect the
quality of their water bodies:
• Adoption of Water Quality Standards. Under CWA Section 303(c),
each state, territory, and authorized tribe is responsible for developing
water quality standards, which consist of three key components: the
designated uses of a water body; water quality criteria, which are
designed to protect those uses; and antidegradation requirements to
protect existing uses and high-quality waters. Water quality criteria can
be either numeric to specifically define the maximum pollutant levels
Top Management Challenge
This audit addresses the following top
management challenge for the
Agency, as identified in OIG Report
No. 20-N-0231. EPA's FYs 2020-2021
Top Management Challenges, issued
July 21, 2020:
• Overseeing states implementing
EPA programs.
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permitted in a water body or narrative to generally describe the desired
conditions of a water body.
•	Control of Point Sources. Discharges into waters of the United States
from a point source require a permit under the CWA's National Pollutant
Discharge Elimination System, or NPDES, program. Under CWA Section
502, point sources include, but are not limited to, the pipes, ditches, and
other discrete conveyances through which factories, sewage treatment
plants, and other facilities discharge pollutants into water bodies.
Authorized states and territories can issue individual or general NPDES
permits that establish a variety of technical, water quality-based, or other
controls for particular pollutants.1 A NPDES individual permit reflects the
site-specific conditions of a single discharger, and a NPDES general
permit covers multiple dischargers with similar operations and types of
discharges. For example, NPDES permits for municipal separate storm
sewer systems, or MS4s, can be individual or general permits, and can
contain language to limit the amount of
trash being discharged or released from
stormwater outfalls into neighboring
water bodies.
•	Management of Nonpoint Sources.
Nonpoint sources of pollution are more
challenging to control because their
sources can be numerous and may not be
easily identifiable. There are many
nonpoint sources of pollution, from farm
fields to urban areas. As water runoff
from rain or snow moves, it picks up
natural and human-made pollutants, such
as trash, and deposits them into surface waters or groundwater. The EPA
reports that the majority of trash pollution comes from nonpoint sources.
To manage trash pollution from nonpoint sources, states and communities
use a variety of approaches, including prohibitions and fines for littering,
and nonregulatory initiatives, including trash capture, source reduction,
and cleanup events.
•	Identification of Impaired Waters. Under CWA Section 303(d), every
two years, states identify and list the water bodies or water-body
segments—that is, portions of water bodies—for which existing pollution
controls are not stringent enough to attain or maintain water quality
standards set by the states or the EPA.
1 As of April 2021, 46 states and the U.S. Virgin Islands are authorized by the EPA to implement a NPDES
permitting program. Idaho is partially authorized, and the EPA fully implements the permitting program in
Massachusetts, New Hampshire, and New Mexico. As of April 2021, no tribe is authorized by the EPA to
implement a NPDES permitting program.
What are MS4s? MS4s are
conveyances or systems of
conveyances—for example, storm
drains, pipes, and ditches—that
collect and discharge stormwater
into local water bodies. MS4s are:
•	Owned by a state, city, town,
village, or other public entity
that discharges to U.S. waters.
•	Not a combined sewer.
•	Not part of a sewage treatment
plant or publicly owned
treatment works.
—EPA's "Stormwater Discharges
from Municipal Sources" webgage
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• Establishment of Total Maximum Daily Loads, or TMDLs. States or
the EPA must prepare TMDLs for the water bodies and water-body
segments listed under CWA Section 303(d) to establish the pollutant limits
necessary to attain and maintain the applicable water quality standards.2
The state then works toward seeing that the established TMDLs are met
either by incorporating the TMDLs into the NPDES permits for point
sources or by identifying and implementing pollution prevention strategies
and examining control opportunities for nonpoint sources.
The Office of Water's program offices and EPA regions assist and oversee state
implementation of these CWA tools. In addition, the Office of Water's Trash Free
Waters Program supports state and local efforts to reduce trash and plastic
pollution from U.S. waterways by disseminating information and providing
technical and financial assistance. The program is implemented by three full-time
EPA staff based in Washington, D.C., and is supported by EPA regional staff who
spend part of their time working on trash projects.
Responsible Offices
Within the EPA's Office of Water, the Office of Wastewater Management
manages the NPDES program for point sources; the Office of Wetlands, Oceans,
and Watersheds manages the nonpoint source, listing, and assessment programs;
and the Office of Science and Technology manages the water quality standards and
criteria programs. The Office of Water works with EPA regional offices, state and
local governments, American Indian tribes, and others to implement the CWA.
Scope and Methodology
We conducted this performance audit from November 2019 to March 2021 in
accordance with generally accepted government auditing standards. Those
standards require that we plan and perform the audit to obtain sufficient,
appropriate evidence to provide a reasonable basis for our findings and
conclusions based on our audit objective. We believe that the evidence obtained
provides a reasonable basis for our findings and conclusions based on our audit
objective.
As detailed in Appendix A, we assessed the internal controls necessary to satisfy
our audit objective.3 In particular, we assessed the internal control components
and underlying principles—as outlined in the U.S. Government Accountability
2	According to the CWA Section 303(d)(2), if the EP A administrator disapproves of a load, the administrator must,
within 30 days, establish loads necessary to implement the water quality standards.
3	An entity designs, implements, and operates internal controls to achieve its objectives related to operations,
reporting, and compliance. The U.S. Government Accountability Office sets internal control standards for federal
entities in GAO-14-704G, Standards for Internal Control in the Federal Government (also known as the "Green
Book"), issued September 10, 2014.
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Office's Green Book—significant to our audit objective. Any internal control
deficiencies we found are discussed in this report. Because our audit was limited
to the internal control components and underlying principles deemed significant
to our audit objective, it may not have disclosed all internal control deficiencies
that may have existed at the time of the audit.
This report addresses the Office of Water's work to reduce trash, including
plastics, in U.S. waterways. To conduct our audit, we met with EPA managers and
staff from the Office of Water, the Office of Research and Development, and the
Office of Land and Emergency Management. We reviewed the state-established
water quality criteria that could cover trash pollution in three states: California,
Maryland, and Missouri. We interviewed water pollution and solid waste
environmental management staff from these three states. We collected information
from EPA regional staff via a questionnaire about state and local activities to
reduce the volume of trash in waterways. We also spoke with staff at
nongovernmental organizations and academic institutions. We analyzed the CWA
and Office of Water documents for information pertaining to trash reduction plans
and regional priorities. We did not review legislation that targets trash removal
from oceans, such as the Marine Debris Act or the Save Our Seas Act 2.0, as such
legislation was outside the scope of this performance audit.
Prior Report
On January 6, 2021, we issued Report No. 21 -N-0052. Office of Research and
Development Initiatives to Address Threats and Risks to Public Health and the
Environment from Plastic Pollution Within the Waters of the United States. We
reported that the EPA's research into plastics is in its early stages and that the
Office of Research and Development has not yet conducted enough research to
determine risks to public health and the environment from plastic exposure. We
issued no recommendations in that report.
Results
The EPA and states have not widely applied all of the tools established by the
CWA to reduce the amount of trash in U.S. waterways. Trash pollution in water
bodies is challenging to control because it is made of up many substances, it is
both a point- and nonpoint-source pollutant, and the EPA has not established
consistent methods for measuring it. States establish narrative, rather than
numeric, water quality criteria for trash pollution, and narrative criteria often
involve subjective assessments. Only ten states and the District of Columbia have
listed water bodies under CWA Section 303(d) as impaired or threatened due to
trash. Of these, only three states and the District of Columbia have developed a
TMDL for trash, in part because there is a lack of information on how to develop
such a TMDL.
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Despite these challenges, thousands of municipalities across the United States
control stormwater discharges of trash through MS4 NPDES permits. In addition,
the EPA, states, and municipalities implement a variety of nonregulatory
initiatives to prevent and remove trash from waterways. The EPA can further
improve upon these efforts by evaluating the regulatory and nonregulatory
obstacles facing states and municipalities and by continuing its support of
initiatives to reduce trash in U.S. waterways.
States Face Obstacles to Establish Measurable Criteria to Achieve
Water Quality Standards Addressing Trash Pollution
States and authorized tribes establish water quality standards that describe the
desired condition of a water body and the means by which that condition will be
protected or achieved. These standards consider the designated uses of the water
body to specify goals and expectations for how the water body will be used and
establish water quality criteria to protect those designated uses.
All three of the states we reviewed established narrative, rather than numeric,
water quality criteria that cover trash pollution. California established narrative
criteria specifically protecting the designated uses of its water bodies from the
effects of trash. The state has provisions in both its inland waterways plan and its
oceans plan to control trash. These provisions state that trash shall not be present
in inland surface waters, enclosed bays, estuaries, ocean waters, and along
shorelines or adjacent areas "in amounts that adversely affect beneficial uses or
cause nuisance." The other two states, Maryland and Missouri, have narrative
criteria that address "floating debris" in amounts sufficient to be unsightly, create
a nuisance, or interfere with designate uses. Under these various narrative criteria,
state water quality managers apply their own judgement to determine how the
trash and floating debris impact the designated uses of water bodies.
Because trash consists of diverse materials, including plastic, state regulators and
EPA staff described ways in which the Agency could provide additional technical
assistance to control trash pollution in water bodies. One state regulator said that
the EPA could better support states by recommending numeric thresholds for the
aesthetic appearance of water bodies or for noncontact recreational uses of water
bodies, such as boating and fishing. Another state regulator explained that EPA
technical guidance for developing narrative criteria would help states characterize
how trash and plastic impair waterways. An EPA water quality manager we
interviewed stated that EPA-developed examples of trash assessment
methodologies could help states determine whether waters are impaired.
To help reduce trash in U.S. waterways, the EPA needs to identify and evaluate the
obstacles that states face when developing and implementing narrative and
numeric criteria, such as the lack of technical guidance regarding the establishment
of such criteria and the lack of examples of trash assessment methodologies.
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Even When States List Trash as an Impairment, Few Establish TMDLs
Under CWA Section 303(d), states submit, and the EPA approves, lists of
impaired and threatened waters every two years. Since 1996, the following ten
states and the District of Columbia have listed about 320 individual water-body
segments as impaired due to trash, debris, or floatables: Alaska, California,
Connecticut, Hawaii, Illinois, Maryland, Massachusetts, Nebraska, New York,
and Pennsylvania.
Once a water body is listed under CWA Section 303(d) as impaired due to trash
pollution, the state shall, per the CWA, develop a TMDL to attain and maintain the
applicable water quality standard. The state, however, prioritizes development of
TMDLs based on the severity of the pollution and the sensitivity of the water
body's designated uses, among other factors. As of March 2021, only the District
of Columbia and three of the ten states that have listed water bodies as impaired
for trash have established TMDLs to control trash pollution:
•	The State of California Water Resources Control Board consists of nine
regional boards. One of these, the Los Angeles Regional Water Quality
Control Board, established trash and debris TMDLs with a numeric target
of zero trash in applicable water bodies.
•	Together, Maryland and the District of Columbia established a trash
TMDL for the Anacostia River, which the EPA approved in 2010.
However, in 2016, a nongovernmental organization challenged the EPA's
approval because the TMDL did not set limits on the volume of trash that
can enter the river; rather, the TMDL established the amount of trash
(100 percent) that must be removed from the river. In 2018, when the
challenge succeeded, the District of Columbia, Maryland, and the EPA
began developing a replacement TMDL in response to this litigation. The
replacement TMDL has not yet been completed.
•	Alaska established several TMDLs that cover trash pollution that were
approved by the EPA, including one in 2000 for the Swan Lake Watershed
in Sitka, one in 2005 for the Jordan Creek in Juneau, one in 2008 for the
Noyes Slough in Fairbanks, and one in 2017 for the Matanuska River in
Palmer. Also, in 2000, EPA Region 10 established a debris and solid
waste TMDL for Duck Creek in Alaska's Mendenhall Valley, with a
numeric target of zero pollution.
Staff in the states we interviewed described challenges with these TMDLs, such
as a lack of an implementation plan for nonpoint sources and CWA authorities.
The EPA needs to identify these and related obstacles so the Agency's technical
resources can assist states' efforts to use the tools established by the CWA to
control trash in U.S. waterways.
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NPDES Permits for MS4s Incorporate Trash Control Requirements,
but Some States Request Additional Assistance
Approximately 7,550 MS4s in the United States hold either an individual or a
general NPDES permit, which regulates their discharges of storm water that may
contain trash and other pollutants into local water bodies. To obtain an MS4
NPDES permit, municipalities must develop stormwater management programs.
These programs should include practices and pollution prevention activities to
reduce the amount of trash flowing into waterways—for example, public
education and outreach, as well as illicit discharge detection and elimination.
Some of these practices from municipalities in the states we reviewed include:
•	"Within one year of permit issuance, the City shall inventory and evaluate
all current trash and recyclable pick-up operations, litter control programs,
and public outreach efforts."
—Individual MS4 permit for Baltimore, Maryland
•	"Permittees shall implement trash load reduction control actions in
accordance with the following schedule and trash generation area
management requirements, including mandatory minimum full trash
capture systems, to meet the goal of 100 percent trash load reduction or no
adverse impact to receiving waters from trash by July 1, 2022."
—Individual MS4 permit for San Francisco, California
Trash control requirements in MS4 NPDES permits can reduce the volume of
trash in U.S. waterways. For example, in 2020, Washington, D.C.'s Department
of Energy and Environment reported that nearly 127,000 pounds of trash were
captured, removed, or prevented from entering the Anacostia River, exceeding the
municipality's goal of 108,347 pounds.
Staff from the California Water Resources Control Board identified two ways in
which the EPA could further support their efforts to use the tools of the CWA
more effectively. They stated that the EPA could provide grant funding to develop
new "Best Management Practices" and to evaluate the effectiveness of existing
best practices to reduce trash from stormwater runoff. They also requested that the
Agency provide a way to incorporate these into MS4 permits.
EPA Programs and Activities Help Reduce Trash in Waterways
The Office of Water's Trash Free Waters program and associated EPA regional
activities aim to reduce the amount of trash generated and prevent trash from
entering the aquatic environment. In 2016, the Trash Free Waters program
published the Aquatic Trash Prevention National Great Practices Compendium,
which contains examples of activities, technologies, and practices to control trash.
The Trash Free Waters program also produces newsletters that contain
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information on current activities, upcoming events, and project funding
opportunities related to trash prevention and reduction.
After we issued our draft report to the Agency, the EPA's Trash Free Waters
program issued two technical guidance documents. The Trash Stormwater Permit
Compendium provides permit writers with information about specific and
measurable trash control provisions for MS4 NPDES permits. The U.S. EPA
Escaped Trash Assessment Protocol defines a consistent methodology for
collecting, identifying, quantifying, and recording trash on land and in waterways.
Regional staff reported other EPA initiatives that involve trash reduction, such as:
•	National Estuary Program. This EPA program aims to protect and restore
the ecological integrity of 28 estuaries of national significance. One way
this goal is achieved is via volunteer cleanup events to help control trash.
For example, five volunteer cleanup events held in fiscal year 2020 for
Florida's Sarasota Bay watershed removed 1,954 pounds of trash.
•	EPA Geographic Programs. The EPA has developed geographic-based
programs to address specific water pollution concerns in its regions. For
example, EPA Region 2's New York and New Jersey Harbor & Estuary
Program is conducting research to assess the types, sources, and
conditions of marine debris in the watersheds of the Passaic, Bronx,
Harlem, and Hackensack Rivers. The EPA Gulf of Mexico Division in
Region 4 partnered with nongovernmental organizations to undertake a
comprehensive assessment of trash sources, transport routes, fate, and
enforcement effectiveness in the Upper Dog River Watershed in Alabama.
They plan to use this information to reduce trash by at least 50 percent in
one stream segment, as well as to develop and test a methodology for
strategically reducing trash and litter throughout the entire watershed.
•	Urban Waters Partnership. The EPA awarded Massachusetts' Mystic
River Watershed Association $15,000 so that volunteers could collect and
categorize trash from various locations to identify major litter areas and
the most prevalent types of trash. In one locality, volunteers removed
80 pounds of trash from waterways.
The EPA and its regional, state, and local partners are working to reduce trash
entering U.S. waters. Through source reduction, cleanup efforts, technical
guidance, and financial assistance, trash pollution can be reduced.
Conclusions
Trash, which includes plastic, is a water pollutant. In U.S. waterways, the
presence of trash and plastic can degrade habitats, harm wildlife, and prevent
designated uses such as fishing or recreation. Ten states and the District of
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Columbia have identified trash as a water quality impairment on CWA
Section 303(d) lists, and three of these states and the District of Columbia have
developed TMDLs related to trash pollution. NPDES MS4 permits are another
regulatory tool that states and municipalities can use to control the volume of
trash entering U.S. waterways. The EPA has developed technical guidance to help
these entities reduce the volume of trash from stormwater discharges, as well as to
estimate the volume of trash on land and in waterways. To control trash more
effectively as a water pollutant, however, the Office of Water needs to identify
and evaluate—and then help mitigate—state and local obstacles to implementing
the tools of the CWA.
Recommendations
We recommend that the assistant administrator for Water:
1.	Evaluate the obstacles to implementing the Clean Water Act to control
trash in U.S. waterways and provide a public report describing those
obstacles.
2.	Develop and disseminate strategies to states and municipalities for
addressing the obstacles identified in the evaluation from
Recommendation 1. These strategies may include guidance regarding how
to develop narrative water quality criteria, consistent assessment and
measurement methodologies, and total maximum daily loads for trash
pollution.
3.	Support state and local municipalities' efforts to control trash through
National Pollutant Discharge Elimination System permits for municipal
separate sewer systems by publishing guidance documents, such as the
Trash Stormwater Permit Compendium and the U.S. EPA Escaped Trash
Assessment Protocol.
Agency Response and OIG Assessment
The Agency agreed with our recommendations and proposed initial corrective
actions in response to our draft report; the EPA's initial response is in
Appendix B. We reached out to the EPA for clarification on the corrective actions
proposed, and the Agency responded on April 19, 2021, with revised corrective
actions (Appendix C). These revised corrective actions meet the intent of our
recommendations.
We consider Recommendations 1 and 2 resolved with corrective actions pending.
With the April 2021 publication of the Trash Stormwater Permit Compendium
and the U.S. EPA Escaped Trash Assessment Protocol, the Agency completed
Recommendation 3.
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Status of Recommendations and
Potential Monetary Benefits
RECOMMENDATIONS






Potential





Planned
Monetary
Rec.
Page



Completion
Benefits
No.
No.
Subject
Status1
Action Official
Date
(in $000s)
Evaluate the obstacles to implementing the Clean Water Act to
control trash in U.S. waterways and provide a public report
describing those obstacles.
Develop and disseminate strategies to states and municipalities
for addressing the obstacles identified in the evaluation from
Recommendation 1. These strategies may include guidance
regarding how to develop narrative water quality criteria,
consistent assessment and measurement methodologies, and
total maximum daily loads for trash pollution.
Support state and local municipalities' efforts to control trash
through National Pollutant Discharge Elimination System permits
for municipal separate sewer systems by publishing guidance
documents, such as the Trash Stormwater Permit Compendium
and the U.S. EPA Escaped Trash Assessment Protocol.
Assistant Administrator 12/31/21
for Water
Assistant Administrator 4/30/23
for Water
Assistant Administrator 4/30/21
for Water
1 C = Corrective action completed.
R = Recommendation resolved with corrective action pending.
U = Recommendation unresolved with resolution efforts in progress.
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Appendix A
Internal Control Assessment
This table identifies which internal control components and underlying principles are significant
to our audit objective.
Internal control components are
significant to the audit objective
Internal control principles are significant to the audit objective
X
Control Environment
The foundation for an internal control
system. It provides the discipline and
structure to help an entity achieve its
objectives.

1. The oversight body and management should demonstrate a
commitment to integrity and ethical values.
X
2. The oversight body should oversee the entity's internal control
system.
X
3. Management should establish an organizational structure,
assign responsibilities, and delegate authority to achieve the
entity's objectives.

4. Management should demonstrate a commitment to recruit,
develop, and retain competent individuals.

5. Management should evaluate performance and hold individuals
accountable for their internal control responsibilities.
X
Risk Assessment
Management assesses the risks facing
the entity as it seeks to achieve its
objectives. This assessment provides
the basis for developing appropriate
risk responses.
X
6. Management should define objectives clearly to enable the
identification of risks and define risk tolerances.
X
7. Management should identify, analyze, and respond to risks
related to achieving the defined objectives.

8. Management should consider the potential for fraud when
identifying, analyzing, and responding to risks.

9. Management should identify, analyze, and respond to significant
changes that could impact the internal control system.
X
Control Activities
The actions management establishes
through policies and procedures to
achieve objectives and respond to risks
in the internal control system, which
includes the entity's information system.
X
10. Management should design control activities to achieve
objectives and respond to risks.

11. Management should design the entity's information system and
related control activities to achieve objectives and respond to
risks.

12. Management should implement control activities through
policies.
X
Information and Communication
The quality information management
and personnel communicate and use to
support the internal control system.
X
13. Management should use quality information to achieve the
entity's objectives.
X
14. Management should internally communicate the necessary
quality information to achieve the entity's objectives.
X
15. Management should externally communicate the necessary
quality information to achieve the entity's objectives.
X
Monitoring
Activities management establishes
and operates to assess the quality of
performance overtime and promptly
resolve the findings of audits and other
reviews.
X
16. Management should establish and operate monitoring activities
to monitor the internal control system and evaluate the results.

17. Management should remediate identified internal control
deficiencies on a timely basis.
Source: Based on internal control components and principles outlined in GAO-14-704G, Standards for Internal
Control in the Federal Government (also known as the "Green Book"), issued September 10, 2014.
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Appendix B
Agency Response to Draft Report
•	•	UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
I W ^	WASHINGTON, D.C, 20460
PRoTfc0"^	OFFICE OF WATER
MEMORANDUM
SUBJECT: Response to the Office of Inspector General Draft Report, Project No.
OA&E-FY 19-0086, "Office of Water Initiatives to Address Threats and Risks to Public
Health and the Environment from Trash, Including Plastic Pollution, Within the Waters
of the United States," dated March 1, 2021
FROM: Radhika Fox
Acting Assistant Administrator
Digitally signed by Fox,
Fox, Radhika "2104.01
13:20:31 -07'00'
TO:
Kathlene Butler
Director
Water Directorate Office of Evaluation
Thank you for the opportunity to respond to the issues and recommendations in the subject draft
evaluation report. Following is a summary of the U.S. Environmental Protection Agency's (EPA
orAgency) overall position, along with its proposed corrective actions on each of the report's
recommendations and estimated completion dates.
AGENCY'S OVERALL POSITION
The Agency appreciates the thoughtful and thorough review of the Office of Water's efforts in
this important area. As noted in previous discussions, new federal legislation related to this area
was signed into law in December 2020 (Save Our Seas 2.0) and addresses water-related actions
that are relevant to this report. We have identified corrective actions for each of the
recommendations and believe that theseactions will significantly advance our efforts to reduce
the levels of trash entering and being carried by our waters.
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AGENCY'S RESPONSE TO DRAFT AUDIT RECOMMENDATIONS
Agreements
No.
Recommendation
High-Level Corrective Action(s)
Est.
Completion
Date
1
Evaluate the obstacles to
implementing the Clean
Water Act to control
trash in
U.S. waterways, and
provide
a public report
describing those
obstacles.
To evaluate the obstacles to implementing the Clean
Water Actto control trash in U.S. waterways,EPA
will address this
recommendation through the development of the
"water management" component of the Federal
Strategy required under Section 301 of Save Our
Seas 2.0. This Strategy will be a public document
addressing both the waste and water components
related to plastic pollution.
December 31,
2021
2
Develop and disseminate
strategies to states and
municipalities for
addressing the obstacles
identified in the
evaluation from
Recommendation 1. For
example, these strategies
may include guidance
regarding how to
develop narrative water
quality criteria,
consistent assessment
and measurement
methodologies, and total
maximum daily loads for
trash pollution.
In response to recommendation 2 OWOW agrees to
issue, in collaboration with EPA Regions, national
303(d) guidance for States highlighting the
requirement to assemble and evaluate all water
quality-related data and information, and use such
data/information to determine if ALL applicable
WQS are attained (including narrative criteria that
encompass trash). The guidance might also include
examples of assessment approaches and address the
variability that may be appropriate among
states/areas, (e.g., WQS can vary significantly
among states, WQS allow for different policy and
technical judgments by states, water conditions can
vary significantly in different regions of the US).
OWOW appreciates that OIG already recognizes
that scientific understanding in this area is still
limited, noting that: "EPA's research into plastics is
in its early stages and that the Office of Research
and Development has not yet conducted enough
research to determine risks to public health and the
environment from plastic exposure."
In FY22, OST will consider assembling a list of
example narrative water quality standards for
trash/plastic pollution as a resource for interested
states and authorized tribes and could also develop a
template for such a narrative.
National
303(d)
guidance to
be addressed
in an
Integrated
Reporting
Memo
(OWOW) -
April 2023.
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Support state and local
municipalities' efforts to
control trash through
National Pollutant
Discharge Elimination
System permits for
municipal separate sewer
systems by publishing
guidance documents
such as the Trash
Stormwater
Compendium and the
Escaped Trash
Assessment Protocol.
To support state and local municipalities' efforts to
control trash through permits, the Trash Free Waters
Program has developed Escape Trash Assessment
Protocol to address the needs of stakeholders who
want more detailed information from an assessment
methodology in order to help them identify tailored
management interventions upstream, and potentially
to inform impaired waterbody
listing-decisions and stormwater permit trash
provisions. EPA will be marketing this protocol
actively upon publication.
Both the Trash Stormwater Compendium and the
Escaped Trash Assessment Protocol will be
published on the Trash Free Waters website, and the
Trash Free Waters program and its partners will be
engaging in marketing efforts to get word out about
these products.	
Trash
Stormwater
Compendium
-July 2021.
Escaped
Trash
Assessment
Protocol -
July 2021.
CONTACT INFORMATION
If you have any questions regarding this response, please contact Tiffany Crawford, the Office of
Water Audit Follow-up Coordinator, at Crawford.Tiffany@epa.gov or 202-566-2375.
cc: John Goodin (OWOW), Sandra Connors (OWOW), Katherine Weiler (OWOW), Brian
Frazer (OWOW), Robert Benson (OWOW), Romell Nandi (OWOW), James Havard (OWOW),
Deborah Nagle (OST), Robert Wood (OST), Shari Barash (OST), Kathryn Gallagher (OST),
Erica Weyer (OST), Andrew Sawyers (OWM), Christopher Kloss (OWM), Wynne Miller
(OWM), Rachel Urban (OWM), Steven Moore (OW), Macara Lousberg (OW), Tiffany
Crawford (OW), Rick Picardi (ORCR), Krystal Krejcik (ORCR), Tim Roach (OIG), Jayne
Lilienfeld-Jones (OIG), Nirvair Stein (OIG), Morgan Collier (OIG).
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Appendix C
Agency Revisions to Proposed Corrective Actions
No.
Recommendation
High-Level Corrective Action(s)
Est. Completion
Date
1
Evaluate the obstacles to
implementing the Clean
Water Act to control
trash in U.S. waterways,
and provide a public
report describingthose
obstacles.
To evaluate the obstacles to implementing the
Clean Water Act to control trash in U.S.
waterways, EPA will engage in discussion with
states, and will address this recommendation
through the development of the "water
management" component of the Federal Strategy
required under Section 301 of Save Our Seas 2.0.
This Strategy will be a public document
addressing both the waste and water components
related to plastic pollution, and will evaluate the
requirements and hurdles posed by the Clean
Water Act, as well as other regulatory
requirements and non-regulatory actions.
December 31,
2021
2
Develop and
disseminate strategies to
states and municipalities
for addressing the
obstacles identified in
theevaluation from
Recommendation 1. For
example, these
strategies mayinclude
guidance regarding how
to develop narrative
water quality criteria,
consistent assessment
and measurement
methodologies,and total
maximum daily loads
for trash pollution.
2.1: In response to recommendation 2 OWOW
agrees to issue, in collaboration with EPA
Regions, national 303(d) guidance for States
highlighting the requirement to assemble and
evaluate all water quality-related data and
information, and use suchdata/information to
determine if ALL applicable WQS are attained
(including narrative criteria that encompass trash).
In developing the guidance, OWOW will work
with regions and states to seek to identify
examples of assessment approaches with regards
to trash, and address the variability that may
beappropriate among states/areas, (e.g., WQS can
vary significantly among states, WQS allow for
different policy and technical judgments by states,
water conditions can vary significantly in
different regions of the US).
OWOW appreciates that OIG already recognizes
that scientific understanding in this area is still
limited, noting that: "EPA's research into plastics
is in its earlystages and that the Office of
Research and Development has not yet conducted
National 303(d)
guidance to be
addressed in an
Integrated
ReportingMemo
(OWOW) -
April 2023.
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enough researchto determine risks to public health
and the environment from plastic exposure."
2.2: OST will compile a list of existing trash and
plastic pollution narrative criteria provisions; and December 2021
2.3: Determine by April 2022 further actions April 2022
based on the breadth and quality of those
narratives
2.4: If EPA determines that there are examples of September 2022
state narratives that are suitable for use by other
states EPA would post example narratives on
EPA's website.
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Appendix D
Distribution
The Administrator
Deputy Administrator
Chief of Staff, Office of the Administrator
Deputy Chief of Staff, Office of the Administrator
Agency Follow-Up Official (the CFO)
Assistant Administrator for Office of Water
Agency Follow-Up Coordinator
General Counsel
Associate Administrator for Congressional and Intergovernmental Relations
Associate Administrator for Public Affairs
Principal Deputy Assistant Administrator for Water
Deputy Assistant Administrators for Water
Director, Office of Continuous Improvement, Office of the Chief Financial Officer
Director, Office of Wastewater Management, Office of Water
Director, Office of Wetlands, Oceans, and Watersheds, Office of Water
Director, Office of Science and Technology, Office of Water
Audit Follow-Up Coordinator, Office of the Administrator
Audit Follow-Up Coordinator, Office of Water
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