UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON, D.C

. 20460



## J

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## 2009

Mr. Michael Sole

, Secretary
Florida Department of Environmental Protection
3900 Commonwealth Boulevard

, Mail Stop 49 

### Tallahassee, F 32399-3000 

# ,

Dear Se OFFICE OF WATER

This letter constitutes a determination under Clean Water Act (CWA) section 303(c)(4)(8) that new or revised water quality standards for nutrients are necessary to

meet the requirements of the CWA for the State of Florida. I am gratified to have learned

that your Department supports EPA's detennination that numeric nutrient water quality

criteria are necessary to meet the requirements of the CW A for the State of Florida.

In considering whether new or revised standards are necessary , EPA recognizes

that Florida has invested over $20 million in collecting and analyzing data on the relationship between nutrient levels and biological impacts for purposes of developing

numeric nutrient criteria and that Florida has implemented some of the most progressive

nutrient management strategie s in the Nation. Moreover

, for over a decade

, the State has developed and demonstrated an impressive track record of commitment, innovation

, and
stakeholder outreach and collaboration in its efforts to manage nutrient-related pollution.

Florida achieved this record not only as a result of its longstanding commitment to environmental protection but also because it recognized the widespread and very substantial nutrient pollution challenges it faces.

Despite Florida ' s widely recognized efforts, substantial water quality degradation

from nutrient over-enrichment remains a significant challenge in the State and one that is likely to worsen with continued population growth and environmental and land-use changes. E PA has determined that nwneric nutrient water quality criteria are nece s sary for the State of Florida to meet the CWA requirement to have criteria that protect applicable designated uses. Additionally

, numeric nutrient criteria will create clear water quality goals and easily measurable quanti t ative baselines to support stronger collaboration and more effective partnersh i ps with both point and nonpoint source dischargers of nutrient pollution.



## @ Printed on Recycled Paper

### 2 Today’s determination affirms the wisdom of the substantial investments that
Florida has made to date in nutrient data collection, analysis, and stakeholder involvement, and is fully consistent with the State’s commitment to a stronger nutrient control program through a greater emphasis on the development of numeric nutrient criteria. Today’s determination will support Florida in building upon its already strong record of water quality prot ection, result in crite ria protective of applicable designated uses, and further expand and strengthen th e numerous partnerships and collaborative projects Florida has led and supported to date.

Statutory and Regulatory Background

Section 303(c) of the CWA requires Stat es and authorized Tribes (hereafter, collectively referred to as “States”) to adopt water quality standards for waters of the United States within their applicable juri sdictions. Section 30 3(c)(2)(A) and EPA’s implementing regulations at 40 CFR part 131 require, among other provisions, that State water quality standards include th e designated use or uses to be made of the waters and the criteria necessary to protect those uses. EPA’s regulations at 40 CFR § 131.11(a)(1) provide that States shall “a dopt those water quality criteria that protect the designated
use” and that such criteria “must be based on sound scientific rationa le and must contain sufficient parameters or constituen ts to protect the designated use.”

States are also required to review their water quality standard s at least once every three years and, if appr opriate, revise or adopt new sta ndards (CWA section 303(c)(1)). States are required to submit these new or revised water quality standards to EPA for review and approval or disapproval (CWA sec tion 303(c)(2)(A)). Fi nally, CWA section 303(c)(4)(B) authorizes the Admi nistrator to determine, evenin the absence of a State submission, that a new or revised standard is needed to meet the CWA’s requirements. When deciding whether a CWA section 303(c)(4 )(B) determination is warranted for a particular state, EPA considers each situ ation based on its particular facts and circumstances. The CWA does not specify particular information or factors that EPA must consider when deciding to exercise its discretion under section 303(c)(4)(B), and
EPA thus considers each individual case on its merits. The authority to make a
determination under CWA secti on 303(c)(4)(B) is di scretionary and resides exclusively with the Administrator, unless delegated by the Administrator. For the purposes of today’s determination, the Administrator has de legated this authority to me, Benjamin H. Grumbles, EPA’s Assistant Administrator for Water.

Florida’s Current Nutrient Program

Florida has taken a number of steps to control nutrient pollution within the State. In addition to adopting a narrative nutrientcriterion and implementing that criterion through NPDES permits, water body assessments , and TMDLs, Florida has established other programs and laws to control nutrient pollution in the State. Despite the State’s substantial efforts, however, EPA concl udes that, based on the available data, information, and trends, Florida’s narrative nu trient criterion alone is not sufficient to

### 3 protect applicable designateduses, and that numeric nutri ent criteria are necessary to meet the requirements of the CWA.

With respect to addressing nutrient pollution, Florida:

(1) has adopted a nutrient- specific narrative criterion in its water quality standards, in addition to detailed nutrien t-specific assessment procedures in its Impaired Waters Rule (IWR), (2) encourages individual watershed mana gement plans through the State’s Basin Management Action Plans (BMAPs), and (3) has enacted other State laws a nd programs regarding point and nonpoint source control such as the Grizzle-Figg Act of 1990.

Florida’s Narrative Water Quality Criterion for Nutrients and the IWR

Florida’s narrative water quality criterion fo r nutrients provides, in relevant part,
that “in no case shall nutrient concentrations of a body of wate r be altered so as to cause an imbalance in natural populati ons of aquatic flora or fauna.” 1 

### Florida’s implementation
of the criterion is based on site-specific detailed biologi cal assessments and analyses together with site-by-site outreach and stakeh older engagement in the context of specific CWA-related actions, specifically National Pollutant Discharge Elimination System (NPDES) permits, total maximum daily lo ads (TMDLs), and assessment and listing
decisions.

When deriving NPDES permit limits, Florid a initially conduct s a site-specific analysis to determine whether a proposed di scharge has the reasonabl e potential to cause
or contribute to an exceedance of the narr ative water quality crit erion in the receiving water or any other affected water. This an alysis first involves examining the proposed discharge to determine, in the case of nutrients, whether the discharge contains phosphorus or nitrogen and second, determin ing the ambient water quality of the receiving water and any other affected waters wi th regard to nutrient levels and biological impacts. In Florida’s case, the State then determines what levels of nutrients would “cause an imbalance in natural populations of a quatic flora or fauna” and translates those levels into numeric “targets” for the receiving water and any other affected waters. If Florida finds that there is reasonable potenti al, the State calculates permit limits stringent enough to ensure that such a discharge will no t cause or contribute to an exceedance of the nutrient target levels (a nd therefore cause an “imbalan ce in natural populations of aquatic flora and fauna”) for the water body and any other affected water bodies.

Accurately determining, on a water-by-wa ter basis for thousands of waters, the
levels of nutrients that would “cause an imba lance in natural populations of aquatic flora or fauna” is a difficult, le ngthy, and data-intensive undert aking. This work involves performing detailed site-specific analyses of the receiving water a nd any other affected waters. If the State has not already completed this analysis for a particular water, it can be very difficult to accurately determine, in the context and timeframe of the NPDES

1 See Florida Administrative Code (F.A.C. rule 62-302-530(47)(b)).

### 4 permitting process, the levels of nutrients that would “cause an imbalance in natural populations of aquatic flora or fauna” and pr ocess NPDES permits in a timely manner. For example, in some cases, adequate “cause and effect” data may take several years to collect and therefore may not be available for a particular water at the time of permitting.

Numeric nutrient criteria in Florida w ould enhance the effectiveness of NPDES permits in protecting designated uses and enable Florida permit writers to derive effluent
limitations without the resource intensive a nd burdensome process of conducting sitespecific analyses to determine the appropriate numeric target value. Therefore, numeric
nutrient criteria would ensure that criteria are in place th at will protect the designated uses of Florida’s waters as required by the CWA and EPA’s implementing regulations.

Having numeric nutrient criteria in place would have a similar effect in development of TMDLs. When developing TM DLs, Florida translates, as it does when determining reasonable potential and deri ving limits in the permitting context, the narrative nutrient criterion into a numeric target that the State determines is necessary to meet the narrative criterion and protect appli cable designated uses. This process also involves a site-specific analysis to determin e the nutrient levels that would “cause an imbalance in natural populations of aquatic fl ora or fauna” in a particular water. Each time a site-specific analysis is conducted to determine what the narrative criterion means for a particular water body in developi ng a TMDL, the State takes site-specific
considerations into account a nd devises a method that works for the data and information
available. EPA maintains that numeric criteri a for nutrients would en able the State to, in a more timely manner, establish TMDLs that identify nutrient reduc tions necessary to protect the designated uses. These resource intensive efforts to interpret the State’s
narrative criterion contribute to delays in implementing the criterion and therefore affect the State’s ability to provide the needed pr otections for applicable designated uses.

In adopting the IWR, Florida took important steps toward improving implementation of its narrative nutrient criterion by establishing and publishing an assessment methodology to identify waters im paired for nutrients. This methodology includes numeric nutrient impairment “threshol ds,” above which waters are automatically deemed impaired. For all other waters, th e IWR specifies a process for conducting sitespecific assessments to enable Florida to determine on a site-specific basis whether there is an imbalance in flora or fauna, before a formal impairment or listing decision can be made for these waters. This site-specific proc ess necessarily results in additional delays in identifying all waters impaired by nutrients ; such a delay would not exist with numeric
criteria.

The thresholds of impairment used in the IWR are expressed as an increasing annual trend in trophic state index (TSI) fo r lakes and chlorophyll-a mean values for streams, estuaries, and open coastal waters. While these impairment thresholds and the site-specific assessment proce sses are useful for identifying impaired waters, significant delays in identifying all nutrient-impaired waters unavoidably resultfrom the need to implement the narrative criterion on a site -specific basis for many waters. Numeric nutrient criteria are necessary to facilitate and expedite the identification of all nutrient

### 5 impaired waters in Florida; thereby pr oviding necessary protec tion for the State’s designated uses, as required by the CWA.

Implementation of the State’s Basin M anagement Action Plans (BMAPs) and Other Florida Laws and Programs for Nutrient Control

As mentioned above, Florida has other innovative and important State programs designed to control nutrient pol lution, such as those adopted to limit nutrient pollution ingeographically specific areas. Numeric nutrient criteria will provide more precise, predetermined targets that will facilitate moreeffective implementation of these programs and provide greater certainty as to the level of water qual ity necessary to protect the State’s designated uses.

One of the State’s innovative programs is the development of Basin Management Action Plans (BMAPs) through which Florida assembles groups of stakeholders to develop plans in order to implement Stat e-adopted and EPA-approved TMDLs. These BMAPs outline strategies to implement TMDLs once they are established and include an implementation schedule, a method for evalua ting the effectiveness of the BMAP, and funding strategies, as well as wa ys to address any future incr eases in pollutant loadings. NPDES permits may also be revised as neces sary in order to implement BMAPs, and permitted dischargers (including storm water and other nonagricultural dischargers) implement Best Management Practices (BMPs) “to the maximum extent practicable” to reduce pollution. Nonpoint source discharger s are also covered by BMAPs, and may demonstrate compliance with the Plan by implementing BMPs or conducting water quality monitoring. 2 

### An essential prerequisite for successful implementation of this critical watershed approach is that the State first mu st undertake the process of determining impairments and then developi ng a TMDL. Timely development of TMDLs, established at levels necessary to protect designated uses, will be facilitated by having numeric nutrient criteria in place so that the State can more effectiv ely and expeditiously implement the State’s BMAP program.

In addition to BMAPs, Florida has imple mented additional innovative approaches to address nutrient pollution. A good example is the 1990 Grizzle-Figg Act, ( see Florida
Statutes 403.086 3 

### ), which requires limits of 5/5/3/1 mg/l (BOD 5 

### /SS/TN/TP 4 

### ) for all domestic wastewater treatment facilities in the Tampa Bay area. In 1999, the Florida State Legislature established Advanced Wast ewater Treatment (AWT) limits at 5/5/3/1 mg/l (BOD 5 

### /SS/TN/TP) for wastewater facilities in the Florida Keys ( see Laws of Florida Chapter 99-395 5 

### ) . Florida has also adopted other rules to limit nutrient pollution in geographically specific areas like the I ndian River Lagoon System, the Everglades Protection Area, and Wekiva Springs. In th ese cases, Florida ha s either specifically limited nutrient pollution in the water body, from point and nonpoint source discharges, limited discharges altogether, or, in the case of the Everglades Protection Area,

2 http://www.waterinstitute.ufl.e du/research/projects/downloads /p001-Ch7_SpringsNutrients.pdf

3 http://www.leg.state.fl.us/Statut es/index.cfm?App_mode=Display_Statu te&Search_String= &URL=Ch0403/Sec086.H
TM

4 Biological Oxygen Demand (BOD 5 ), Suspended Solids (SS), Total Nitr ogen (TN), and Total Phosphorus (TP)

5 http://laws.flrules.org /files/Ch_1999-395.pdf

### 6 constructed stormwater treatment areas that can remove nutrients from runoff. Implementation of these types of programs could be refined and enhanced if decision
makers are aware of the numeric nutrient crite ria that are necessary to protect designated

uses.

Magnitude of Nutrient Ov er-Enrichment in Florida

Water quality degradation due to nut rient over-enrichment is a significant
environmental issue in Florida. Florida’s Department of Environmental Protection has acknowledged and documented the magnitude of over-enrichment. According to Florida’s 2008 Integrated Report, 6 

### approximately 1,000 miles of rivers and streams, 350,000 acres of lakes, and 900 square miles of es tuaries are impaired for nutrients in the State. To put this into context, these valu es represent approximately 16% of the assessed river and stream miles, 36% of the assessed lake acres, a nd 25% of the assessed square
miles of estuaries that Florid a has listed as impaired unde r the IWR. The actual number of miles and acres of waters impaired for nutrients is likely higher, as many waters currently classified as “unassesse d” may also be impaired.

This conclusion is based upon a range of av ailable information, including the vast amounts of monitoring data that exist on nutrient-related parame ters in Florida waters. With almost 800,000 nutrient-related data points in STORET (i ncluding nitrogen, phosphorus, chlorophyll-a, and turb idity), Florida has substantia lly more data points than any other State or Territory to clearly characterize the magnitude of its nutrient challenges.

Monitoring Data and Impairments Indicate that Nutrient Problems Persist in Florida

An analysis of United States Geologi cal Survey (USGS) monitoring data for
nutrients in certain locations in Florida show s that levels of nutrient pollution have not significantly improved since 1980 despite strong efforts to control nutrient pollution. Concentrations of Total Phosphorus (TP) and Total Nitrogen (TN) have remained relatively constant at an average of 0.15mg/L and 1.4mg/L, respectively. 7 

### Additionally, Florida’s recurrent harmful algal blooms con tinue to pose threats to public drinking water supplies and recreational sites. Harmful alga l blooms that occur inland and near shore are typically caused by excess nutrients. 8



### Nutrient pollution in Florida has a predictable and widespread impact. The extent of this impact has been well documented a nd tracked for many years. According to Florida’s most recent EPA-approved CWA section 303(d) list from 2002, 9 

### of the 823 waters listed as impaired in Florida, over 60% (over 550 waters) are impaired for
nutrients.

6 http://www.dep.state.fl. us/water/docs/2008_Integrated_Report.pdf

7 USEPA. 2000. STORET Legacy Data Ce nter. http://www.epa.gov/storet/dbtop.html

8 http://www.dep.state.fl.us/water/ tmdl/docs/2006_Integrated_Report.pdf

9 http://www.dep.state.fl.u s/water/tmdl/adopted_gp1.htm

### 7 Florida’s Environment is Unique and Presents Special Challenges

Florida’s natural physical factors, including flat topogr aphy and numerous wetlands, a warm and humid climate, nutrien t-rich soils, hydrology, and erosion caused by tropical storms and hurricanes make c ontrolling nutrient pollution particularly challenging because these conditions are especially conducive to nutrient overenrichment. In addition, human caused impact s such as hydrological modifications (i.e., canals), intensive agricultura l production, population growth and associated urban and suburban development have had a broad and wi despread effect. E ffectively addressing current nutrient impairments in the State re presents a significant challenge and is compounded by a projected population growth of almost 80 percent in Florida from 2000
to 2030. 10 

### Further development and urbanization will likely result in increased nutrient runoff and pressure to utilize remaini ng agricultural lands more intensively. 11



### Within the continental United States, Florida possesses unique and nationally valued aquatic ecosystems, including shallow coral reefs, freshwater and salt marshes, swamps, and mangroves. 12 

### These aquatic ecosystems are particularly sensitive to the
effects of excessive nutrients which threaten the State’s significant biological diversity. The number of species in Florida (3,500 native vascular plan ts and 1,500 vertebrates) is higher than in all but three other states. Fu rther, Florida also ha s many endemic species (410 invertebrates, 258 plants and vertebrates) that ar e not found anywhere else on
Earth. 13 

### Florida has many water-filled caves and sinkholes that se rve as hotspots of biological diversity and provide homes to ma ny species of aquatic life, some unique to particular Florida locations. 14 

### Additionally, Florida is the only state in the continental
United States to have extensive shallow coral re ef formations near its coasts (i.e. within five miles). 15 

### A recent study initiated by the United Nations Food and Agriculture Organization found that the sing le richest concentration of marine life in the Atlantic Ocean lies some 10 miles off the tip of Southern Florida within the Florida Straits. 16 

### This biological diversity relies on sufficient qual ity habitat and othe r natural resources, including clear, transparent waters lo w in phosphate and nitrogen nutrients. 13, 14 

### Especially in the case of cora l reefs and flora and fauna in natural spring environments, clear water with plenty of light and oxygen available is cr itical to the protection of the species that inhabit these locations. Nu trient enriched water can have reduced transparency and low dissolved oxygen levels that are not protective of the natural biology in Florida. Effectively managing nutrient levels in Flor ida’s lakes, flowing waters, estuaries and coastal waters through numeric nutrient criteria is important to maintaining the ecosystems in these waters and important ecosystems that are near shore.

The combined impacts of urban and agricultural activities along with Florida’s physical features and important and unique a quatic ecosystems make it clear that the

10 http://www.census.gov/population/ projections/SummaryTabA1.pdf

11 http://www.dep.state.fl.us/wa ter/docs/2008_Integrated_Report.pdf

12 http://sofia.usgs.gov/publications/ofr/2005-1021/

13 http://edis.ifas.ufl.edu/CR004

14 http://www.floridasprings.org/anatomy/life/

15 http://www.dep.state.fl.us/c oastal/habitats/coral.htm

16 http://www.scienceblog.com/community/older/2003/D/20031748.html

### 8 current use of the narrative nut rient criterion alone is insufficient to ensure protection of applicable designated uses. Numeric nutrien t criteria will strengthen the foundation for identifying impaired waters, preparing TM DLs and developing NPDES permits, as well as support the State’s ability to effectively partner to with point and nonpoint sources to control nutrients, thus providi ng the necessary protection for the State’s designated uses.

Determination

Nutrient pollution in Florida remains a significant and growing challenge. Recognizing this, Florida has invested tens of millions of dollars in the collection of data
to establish the cause and effect relationshi p between nutrients and biological conditions in order to be well positioned to establish what the State, itself, believes are much needed numeric nutrient water quality criteria. As discussed above, despite Florida’s considerable data collection and analysis effo rts and outreach with st akeholders to date, the State is relying on its narrativ e nutrient criterion, the appl ication of which is resource intensive, time consuming, and less than eff ective in implementing programs to protect water quality and prevent impairments of designated uses du e to nutrient overenrichment. The very substantial and widespread nature of nutrient challenges faced by the State and the barriers to effective implementation associated with narrative nutrient criteria in Florida, such as the need for numerous, highly technical site-specific analyses prior to the development of water quality- based effluent limitations in NPDES permits and TMDLs, strongly support th e need in this case for numeric nutrien t criteria to effectively protect designated uses and pr event impairments. In many circumstances,
narrative criteria can be an eff ective tool for protecting design ated uses, particularly when the scope and nature of the environmental problem is easily and clearly defined and derivation of appropriate control measures can be effectively and expeditiously accomplished (e.g., toxic pollutants and bioassessm ents). However, achieving faster and more effective progress in water quality protectio n with regard to nutrients is critical in Florida due to the significant and far-reaching impacts of nutrient pollution on the unique and highly valued aquatic ecosy stems that exist in the Stat e. In this case, numeric nutrient criteria are needed to pr otect Florida’s designated uses.

While Florida has made headway on this issue by developing a methodology in the IWR that allows the State to automatically list certain waters with higher levels of nutrients, Florida still must conduct case-by -case assessments to determine if an
imbalance in flora or fauna exists for waters below the IWR impairment thresholds. The existence of numeric nutrient criteria will facilitate Florida’s efforts to identify all nutrient-impaired waters. Quantifiable nutri ent criteria also wi ll facilitate Florida’s efforts to establish TMDLs and appropriate WQBELs in NPDES permits as necessary to adequately protect applicable designated uses. It will al so create a strong and clear baseline against which to measure progre ss and upon which to support stronger and more effective point and nonp oint partnerships.

For all of these reasons, EPA hereby de termines under CWA section 303(c)(4)(B) that new or revised water quali ty standards for nutrients in the form of numeric nutrient criteria are necessary in the State of Florida to meet the requirements of the CWA (CWA

### 9 section 303(c)(2)(A) and 40 CFR § 131.11(a)(1)). Numeric nutrient criteria will enable the State to implement nutrient controls mo re broadly, effectively, and expeditiously to protect applicable designated uses and meet the challenge of the extent and severity of nutrient pollution in Florida. EPA notes that it has not previously made a determination
on whether numeric nutrien t criteria are necessary in Florida, and clarifies this point so as to resolve any questions that may previ ously have arisen on this issue.

EPA’s Expectation Regarding a Remedy to this Situation

Section 303(c)(4) of the CW A requires that the Administrator promptly prepare and publish proposed regulations setting forth a new or revised water quality standard
when the Administrator makes a determination. EPA will move forward to develop federal proposed regulations setting forth numeric nutrient criteria for Florida and expects
that these criteria will be developed in a manner that ensures that there will be no imbalance in natural populations of flora and fauna in Florida waters. EPA will work collaboratively with Florida’s technical expert s to generate data and conduct analyses.
EPA understands that Florida has an exte nsive stakeholder outreach and comment process underway and has already committed to share with EPA the public comments and stakeholder input received by Florida in th is process, so that EPA may consider this input as it develops the federa l proposal. EPA intends that the criteria will be protective of applicable designated uses, based on sound scientific rationale, responsive to the specific needs of Florida’s waters, and suffi cient to meet the needs of the State’s complete suite of water quality management tools.

In terms of schedule, the State of Fl orida has made significant progress in collecting data needed to adopt nutrient criteria for its lakes and flowing waters. Florida expects to complete data collection, laborat ory analysis of the data, and compilation of the data by March 2009. EPA anticipates th at six months will then be required to complete detailed analyses of the data to identify the relations hips between nutrient causal variables, e.g. nitrogen and phosphorus, and key response variables, e.g., chlorophyll a, Secchi depth, periphyton, and di ssolved oxygen (DO). This analysis will be an important step in developing the numeric nutrient criteria. EPA expects that an additional four months will be needed to organize, document and assemble the complex technical analysis and admi nistrative record to support and prepare the preamble and federal proposal for publication.

For estuaries and coastal waters, Florida is working to compile and assess the adequacy of the data available to develop nutrient criteria. EPA has reviewed the State’s progress and assessed the remaining work associat ed with this analysis and estimates that 12-24 months will be necessary to develop these criteria values, reflecting the broader
technical uncertainties and additional evaluati on that will be necessary to determine cause and effect relationships between nutrients a nd biological response parameters in these waters. Additionally, there is a possibility th at additional data collection may be needed should the analyses yield inconclusive results.In co nclu s i o n , E P A ex p e ct s to pr o p ose numeri c nutri e nt criteri a f o r l a kes a nd
fl ow in g wa t e r s within 1 2 m o nth s, and f o r es tuari es and coas t a l w at e r s, w ithi n 24 m o nth s. E PA expec t s to w or k cl ose ly and co ll abo r at i vely w ith the Sta t e of Fl or i da t o e n sure th at

t h ese nu mer i c n u tri e nt c r it e ri a are p r o t ec t ive of appli cable des i g n a t ed uses , based o n

sou nd scie n t i fic r at i o n a l e, responsive to the s pe c ifi c needs of Flo ri da's wa t e r s, respo n sive

t o avai l a bl e publi c and stakeho lder i np u t, and s u ffic i en t to m eet th e n ee d s of t h e S tat e's compl e t e s uit e o f water qu a lity man age m e nt t o ol s. As a l ways, in th e e ve nt th a t F lorid a ad o pt s a nd EPA a p p r oves n ew or rev i se d wa t e r qual it y s t a nd a rd s that s uffi c i e ntl y address thi s d e t e rmin at i o n b efo re E PA pr o mul gat e s federal water quali t y s t andards, EPA w ou ld

n o l o n ge r be o b liga t ed to p r o mul gate f ede r al wa t e r qu a lit y s tand ar d s.

# in**~4~** 

# 1

j a mi n I

- I. G rum bles
Ass i sta nt Ad mini st r ator

cc: M r

. Jimm y P a lmer, R egio n al A d m i nistra t or, EPA Reg i o n 4
Mr

. Jame s D

. Giatt in a, Dir ecto r , Wa t e r M an age m ent D i v i sion, EPA Reg i o n 4



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