OF THE UNITED STATES 

Many Water Quality Standard . 

Violations May NotBe Significant 

Enough To Justify c&y l%eventive’Actions 

Advanced waste treatment for municipal sewage may not be worth the tremendous costs-- 

estimated by the Environmental Protection 

Agency at $10 billion--unless it will make a 

substantial difference to water quality. In setting or revising water quality standards, States 

generally do not consider costs, and many 

standards are based on questionable data. A 

number of costly advanced waste treatment 

plants may have little effect on water quality. 

This report presents a number of options to 

the Congress concerning the funding of advanced waste treatment projects. It also makes 

recommendations to the Administrator of the 

Environmental Protection Agency to help improve the way water quality standards are set 

and implemented and the procedures used 

in assessing the need for advanced waste 

treatment. 

II II llllllll 

112731 

CED-80-88 

JULY 2,198O 
. 

‘1 

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COMPTROLLER GENERAL OF l-NE UNITED STAT= 

WASHINOION. D.C. 20546 

B-166506 

To the President of the Senate and the 

Speaker of the House of Representatives 

This report discusses the Environmental Protection 

Agency's Construction Grants Program and the significance 

of advanced waste treatment to prevent violations of water 

quality standards. 

We made our review because of congressional concern about 

how water quality standards affect the degree of wastewater 

treatment needed by municipalities. The Congress was especially concerned about the large costs generally associated 

with advanced wastewater treatment. 

Copies of this report are being sent to the Director, 

Office of Management and Budget; the Chairman of the Council 

on Environmental Quality; and the Administrator, Environmental 

Protection Agency. 

of the United States 
, 
COMPTROLLER GENERAL'S MANY WATER QUALITY STANDARD 

REPORT TO THE CONGRESS VIOLATIONS MAY NOT BE 

SIGNIFICANT,ENOUGH TO JUSTIFY 

COSTLY PREVENTIVE ACTIONS 

__---- DIGEST 

The Environmental Protection Agency 

administers a Construction Grants Program 

under the Federal Water Pollution Control 

Act, as amended, commonly referred to as the 

Clean Water Act, to restore and maintain the 

quality of the Nation's waters. The Agency 

estimates that $10 billion will be needed 

through the year 2000 to construct advanced 

waste treatment facilities for municipal 

sewage for this program. 

GAO discussed advanced waste treatment with 

Federal and State water quality officials 

and consultants knowledgeable of water quality 

matters and reviewed various scientific studies 

on water quality. Based on these discussions 

and reviews, GAO found that advanced waste 

treatment-- which removes some pollutants left 

after secondary treatment--with few exceptions, may not be justified. GAO found that: 

--Mathematical models used to predict water 

quality are often imprecise and inexact. 

--Federal funding is insufficient to achieve 

water quality standards for all waterways 

within a reasonable time. 

--The Environmental Protection Agency makes 

it difficult for States to relax or downgrade water quality standards. 

--Relating the impact of various treatment 

levels to water use is difficult.. (See 

pp. 18, 23, 24, 45, and 69.) 

Each State has developed water quality standards 

to protect its waterways and the uses it plans 

to make of them. The standards help determine 

the type of wastewater treatment needed to 

protect waters for those uses. 

CED-80-86 

Iear Sheet . Upon removal, the report 

cover date should be noted hereon. i 
Advanced treatment, which may be required in 

municipalities, is very expensive. Costs rise 

in relation to pollutants removed--the more 

pollutants removed, the higher the costs. 

States generally do not consider costs, 

'however, in setting or revising water quality 

standards. (See pp. 42 to 44.) 

VIOLATIONS MAY NOT BE SIGNIFICANT 

Violation of a water quality standard may not 

always mean that significant environmental, 

social, or public health damage has occurred. 

The seriousness of a violation depends on a 

number of factors. For example: 

--The scientific basis for the standard may 

be questionable.. GAO's review showed that 

water quality levels needed to protect 

water for a designated use are sometimes 

based on limited experimental investigation 

and that competent scientists disagree 

about the effects of water quality on 

aquatic life. 

--The water may not be important to society. 

Some streams are virtually inaccessible-- 

guarded by canyons, steep slopes, or other 

physical barriers. Others offer no public 

access or access only to a few hikers. In 

low-population areas some streams may receive 

very little use. In these situations water 

quality standard violations are not as harmful 

as violations in heavily used waters. 

GAO noted that a number of advanced waste 

treatment plants, either planned, under construction, or in operation, offered questionable benefits. The Appropriations Conference 

Committee in 1979 directed that environmental 

and public health benefits must be considered 

significant before such plants can be approved 

for construction. However, the Clean Water 

Act does not impose.such a requirement. (See 

pp. 5 to 17 and 53 to 67.) 

PREDICTING WATER QUALITY 

STANDARD VIOLATIONS IS UNCERTAIN 

'In many instances municipalities are 

constructing treatment facilities more 

ii 
sophisticated than secondary to prevent 

predicted water quality standard violations. 

These predictions are generally based on 

mathematical models. GAO's review showed 

that the models being used produce highly 

uncertain results. When poorly developed 

or improperly applied, the models frequently 

cannot simulate complex natural processes, 

and adequate water quality data is either 

not used or not available. Many natural 

processes are too complicated for modeling 

to determine whether advanced treatment 

is needed. 

Modelers could improve their techniques. 

For example, nonpoint source pollution 

(runoff from agricultural and forest lands 

and storm runoff from urban areas) should 

be considered, water quality data should 

be reliable and adequate, and the model's 

predictive reliability should be specified. 

(See pp. 18 to 41.) 

COSTS HAVE NOT BEEN 

CONSIDERED ADEQUATELY 

The law does not require communities to 

'consider adequately the costs of achieving 

water quality standards. Although EPA 

generally assumes that the economic feasibility of achieving a standard will be determined 

before standards are set, most standards have 

not received such analysis. Almost all of the 

State officials in the 12 States GAO visited 

said they did not perform rigorous economic 

analyses before setting standards. As a 

result, States tended to classify most of 

their waterways as fishable/swimmable--which 

often necessitates advanced treatment. 

It is difficult for States to reclassify 

streams downward and may become even more 

difficult in the future because the Agency 

discourages downgradings. Agency officials 

said a State is expected to ensure the 

economic reasonableness of attaining the water 

uses it designates in a standard. They said 

that when a body of water is given a fishable/ 

swimmable designation, the Agency presumes 

that the State had determined the economic 

Tear Sheef iii 
reasonableness of attaining the necessary 

water quality for that use. (See pp. 42 

to 52.) 

THE CONGRESS IS CONCERNED ABOUT 

PROJECTS HAVING INSIGNIFICANT 

ENVIRONMENTAL AND PUBLIC HEALTH 

IMPROVEMENTS 

The Clean Water Act allows advanced waste 

treatment plants to be built regardless of 

environmental impact or cost. However: in 

1979 the Appropriations Conference Committee 

stipulated that Construction Grant Program 

funds could be used for advanced waste treatment only if (1) the incremental cost of the 

treatment is $1 million or less or (2) the 

Agency Administrator personally determines 

that advanced treatment is required and that 

it will definitely result in significant 

water quality and public health improvements. 

During July 1978 hearings before the Subcommittee 

on Oversight and Review, House Committee on 

Public Works and Transportation, GAO and others 

pointed out a number of questionable advanced 

waste treatment projects. During fiscal year 

1979, the first year of the Appropriations 

Conference Committee restriction, the Agency 

acted on 26 projects where advanced waste 

treatment cost more than $1 million and the 

Agency's regional administrators acted on 

178 projects involving $1 million or less. 

These actions included approval of the entire 

project as proposed, approval of a portion 

of the project, or deferral of all or a 

portion of the project. 

GAO's review of nine of these projects showed 

that, for most, the Agency's review process 

did not indicate that advanced waste treatment 

would definitely result in significant water 

quality and public health improvements. For 

example, the Agency's analysis of the projects 

did not show the: 

--Significance of the projects' advanced 

treatment portion to the environment. Rather, 

the analysis discussed the project as a whole 

and failed to distinguish between secondary 

treatment and advanced treatment. 

iv 
--Effect on public health. There was little 

indication that the projects would produce 

significant health improvements or that they 

were intended to do so. 

--Significance of the advanced waste treatment 

portion on established waterway uses. Little 

analysis had been done to determine how the 

advanced treatment portion would improve water 

uses. 

--Social significance or benefits of the 

projects. Little, if any, documentation 

existed showing how many more persons would 

be able to fish, swim, or boat on the waterway. 

(See pp. 55 to 58.) 

RECOMMENDATIONS TO THE ADMINISTRATOR, 

ENVIRONMENTAL PROTECTION AGENCY 

GAO recommends a number of corrective measures 

to improve the process for setting and implementing water quality standards and to better 

assess the need for advanced waste treatment. 

(See pp. 69 to 70.) 

AGENCY COMMENTS AND GAO EVALUATION 

In commenting on a draft of this report, 

the Agency agreed with GAO that the Nation's 

water pollution control program is costly and 

complex. But it generally did not agree with 

GAO's conclusions, stating they reflect a misunderstanding of the legislative objectives 

and fail to recognize that States may legally 

set their own water quality standards. 

GAO recognizes that the Congress wanted to make 

" all 'I waters fishable and swimmable, but only 

"wherever attainable." Although the Congress 

did not require the Agency to weigh benefits 

against the costs of building advanced waste 

treatment, it did recognize that the fishable/ 

swimmable goal was not attainable in all cases. 

In fact, the Agency itself directs States to 

consider "environmental, technological, social, 

economic, and institutional factors" in determining attainability. Therefore, GAO continues 

to believe that costs should be considered in 

setting water quality standards and in determining the need for advanced waste treatment. 

Wee PP- 70 to 73.) 

Tear Sheet 

V 
MATTERS FOR CONSIDERATION --- BY THE CONGRESS 

GAO is presenting for congressional consideration 

several options that would give the Agency the 

flexibility to more closely consider costs in 

explaining the need for advanced waste treatment 

projects. (See pp. 73 to 74.) 

vi 
_-_---mm Contents 

Page 

DIGEST 

CHAPTER 

i 

1 INTRODUCTION 

The nature and function of 

water quality standards 

Water quality standards and 

advanced waste treatment 

Scope of review 

2 MANY WATER QUALITY STANDARD 

VIOLATIONS MAY NOT BE SIGNIFICANT 

Violations may be ecologically 

insignificant 

The scientific basis for 

some standards is questionable 

General standards do not 

fit all waters at all 

times of year 

Some violations may not 

cause problems 

Violations may be socially 

insignificant 

Some natural waters are 

of little value to 

society 

Significance of violations 

is reduced if other highquality waters are 

available 

3 PREDICTING WATER QUALITY 

VIOLATIONS BY USING MATHEMATICAL 

MODELS IS VERY UNCERTAIN 

Modeling is a complicated 

process 

Modelers must consider 

major factors that are 

hard to determine 

Biochemical oxygen demand and 

ammonia measurements require 

painstaking analysis 

1 

1 

1 

3 

5 

5 

5 

10 

14 

15 

15 

16 

18 

19 

20 

22 
Many water quality processes cannot 

be accurately modeled 

Methods for estimating stream 

reaeration and oxygen production 

are subject to substantial 

variation 

Water quality data can be 

subject to measurement errors 

Many models are not properly 

applied 

The impact of nonpoint source 

pollution is often overlooked 

Inadequate data is used 

Many models are not properly 

verified 

Some decisionmakers are beginning 

to question modeling results 

Some advanced treatment 

facilities are built in phases 

and only after stream surveys 

show that further water quality 

improvements are needed 

Blanket effluent limits are 

sometimes used in lieu of 

modeling for certain types 

of water bodies 

Effluent limits more stringent 

than secondary are limited 

based on cost or operational 

constraints 

23 

24 

26 

28 

28 

29 

36 

39 

40 

40 

40 

4 THE HIGH COSTS OF GOING BEYOND SECONDARY 

TREATMENT ARE NOT ADEQUATELY 

CONSIDERED IN SETTING STANDARDS 42 

AWT is expensive 42 

Capital costs 42 

Operation and maintenance 

costs 42 

Costs of other needed environmental 

improvements 43 

Counterbalancing environmental 

effects 43 

Costs have not been adequately 

considered in setting standards 44 

The standard-setting process 

assumes costs will be analyzed, 

but they seldom are 44 

Overclassification may be common, 

but reclassifying a water body 

downward is no easy matter 45 
5 

Variances require similar 

justification 

Downward reclassifications may 

become even more difficult 

EPA allows only limited cost 

considerations in the use 

designation process 

EPA.has effectively minimized 

the States' ability to 

tailor WQS to local 

conditions 

QUESTIONABLE AWT PROJECTS ARE 

BEING FUNDED 

Inadequate justification in prior 

years for AWT 

The significance and/or certainty 

of environmental benefits 

expected from large-scale AWT 

projects continue to be 

questionable 

Rochester, Minnesota 

St. Petersburg, Florida 

Walworth County, Wisconsin 

Leominster, Massachusetts 

Many inappropriate small-scale 

AWT projects are still being 

approved 

Sac City, Iowa 

New Concord, Ohio 

Sulphur Springs, Texas 

Sandusky, Michigan 

The congressional restriction on 

AWT projects has been weakened 

Various types of AWT exempted 

Revised public health 

requirement 

High level of certainty not 

adequately considered 

The requirement for significant 

water quality improvement is 

subject to various interpretations 

Conflict between the Clean Water Act 

and the Appropriations Conference 

Committee restriction 

49 

50 

50 

52 

53 

53 

55 

56 

56 

57 

57 

58 

58 

59 

59 

60 

60 

60 

61 

62 

63 

64 
6 CONCLUSIONS, RECOMMENDATIONS, AGENCY 

COMMENTS, AND OUR EVALUATION 67 

Conclusions 67 

Recommendations to the EPA Administrator 69 

Agency comments and our evaluation 70 

Matters for consideration by the 

Congress 73 

APPENDIX 

I Recap of important modeling considerations 

for selected AWT projects proposed for 

the Administrator's approval 75 

II Letter dated February 5, 1980, from the 

Assistant Administrator for Planning 

and Management, Environmental Protection 

Agency 76 

ABBREVIATIONS 

AWT 

BOD 

DO 

EPA 

GAO 

q/l 

O&M 

w/l 

USGS 

WQS 

advanced waste treatment 

biochemical oxygen demand 

dissolved oxygen 

Environmental Protection Agency 

General Accounting Office 

milligrams per liter 

operation and maintenance 

micrograms per liter 

U.S. Geological Survey 

water quality standards 
GLOSSARY 

Advanced waste 

treatment 

Algal blooms 

Treatment processes which remove 

additional pollutants from wastewater 

beyond those eliminated by primary 

and secondary treatment. There are 

different degrees of advanced 

treatment with substantially different costs. Advanced waste treatment processes may remove nutrients 

such as phosphorus and nitrogen, 

a high percentage of suspended solids, 

and oxygen-demanding substances. 

Prolific growths of algae that may be 

stimulated by phosphorus and nitrogen 

in water. Algae can severely decrease 

the oxygen dissolved in the water; 

certain species can cause taste and 

odor problems. The advanced waste 

treatment processes of denitrification 

and phosphorus removal are designed to 

prevent algal blooms in waste-receiving 

waters. 

Biochemical 

oxygen demand The oxygen consumed in waste 

decomposition. 

Dissolved oxygen The oxygen freely available in water. 

Dissolved oxygen is vital to fish and 

other aquatic organisms and for the 

prevention of offensive odors. Traditionally, dissolved oxygen has been 

accepted as the single most important 

indicator of a water body's ability 

to support desirable aquatic life. 

Secondary treatment and advanced waste 

treatment are generally designed to 

protect dissolved oxygen in 

waste-receiving waters. 

Effluent A wastewater discharge. 
Effluent 

limitations Restrictions established by a State or 

EPA on quantities, rates, and concentrations in wastewater discharges.' 

Kinetic rate 

coefficient 

A number that describes the rate at 

which a water constituent (such as biochemical oxygen demand or dissoved 

oxygen) increases or decreases. 

Modeling Mathematical techniques for predicting 

the effect of waste treatment on water 

quality. 

Nonpoint sources Sources of pollution that are difficult 

to pinpoint and measure. Common 

examples.are runoff from farms, forests, 

mines, construction sites, and city 

streets. 

Nutrients 

Point sources 

Pollution 

(of water) 

Elements or compounds essential for 

growth and development of organisms; 

for example, nitrogen and phosphorus. 

Sources of pollution that can be 

readily identified, such as factories 

and sewage treatment plants. 

Contamination or other alteration of the 

physical, chemical, or biological properties of water-- including changes in 

temperature, taste, color, or odor--or 

the discharge into the water of any 

liquid, gaseous, radioactive, solid, or 

other substance that may create a 

nuisance or render such water detrimental or injurious to public health, 

safety, or welfare. 

Primary waste 

treatment 

Treatment usually involving screening 

and sedimentation for removing the 

larger solids in wastewater. The process removes about 30 percent of 

carbonaceous biochemical oxygen demand 

from domestic sewage. 
Secondary waste 

treatment 

Suspended 

solids 

Wasteload 

allocation 

Water quality 

criteria 

Water quality 

standard 

Treatment following primary treatment 

that uses biological digestion and 

additional settling to reduce 

biochemical oxygen demand by 80 to 

90 percent. 

Small particles suspended (not dissolved) 

in water. Very small particles are difficult to remove by conventional means. 

The maximum load of pollutants each discharger of waste is allowed to release 

into a particular waterway. Discharge 

limits are usually required for each 

specific water quality criterion being 

violated or expected to be violated. 

Specific levels of water quality 

which, if not violated, are expected to 

render a body of water suitable for 

its designated use. 

A legal designation of the desired use 

for a given water body and of the water 

quality criteria appropriate for that 

use. 

INTRODUCTION 

THE NATURE AND FUNCTION 

OF WATER OUALITY STANDARDS 

CHAPTER 1 

One goal of the Federal Water Pollution Control Act, 

as amended, commonly referred to as the Clean Water Act, 

is to achieve by mid-1983, wherever attainable, water 

quality that provides for 

--the protection and propagation of fish, shellfish, 

and wildlife and 

--recreation in and on the water. 

These are commonly called the fishable/swimmable goal. The 

act requires States or, if necessary, the Environmental 

Protection Agency (EPA) to set and/or maintain appropriate 

water quality standards (WQS) for both interstate and intrastate waters. WQS must include (1) a designation of a use 

or uses for a given body of water (for example, swimming, 

fish habitat, or public drinking water supply) and (2) water 

quality criteria specifying the type of water quality needed 

to protect the designated use(s). 

EPA has recommended water quality criteria for various 

water uses and requires States to justify less stringent 

criteria. States may require higher water quality than EPA 

recommends. According to EPA officials, EPA is precluded 

by the act from reviewing State criteria for excessive 

stringency, and it does not do so. 

WQS serve several functions. In particular, standards 

may form the basis for: 

I. 

--Requiring treatment beyond secondary for 

municipalities. 

--Controlling nonpoint sources (such as agricultural 

runoff). 

WATER QUALITY STANDARDS AND 

ADVANCED WASTE TREATMENT' 

Theoretically, WQS are to be developed as follows: 

--First, the desired use(s) are designated for a 

body of water (for example, domestic or agricultural 

water supply, swimming, fishing, or boating) after 

considering the costs of attaining the use(s). 

1 
--Second, water quality characteristics (temperature, 

dissolved oxygen (DO), heavy metals, toxic substances 

and others) related to the designated use(s) acre 

identified and concentration limits (water quality 

criteria) are set.for those that -- cannot -. be violated 

without interfering with the designated use(s). 

--Third, the quality of the existing water is analyzed 

and accurate, scientific models are developed to predict water quality after all point source dischargers 

have secondary treatment (or its industrial equivalents). If water quality will not meet the standards, 

the models must accurately determine the additional 

treatment needed. This additional treatment is 

called advanced waste treatment (AWT). 

In practice, however, it does not always work that way. 

Many difficulties prevent this approach from producing 

reliable results. Estimating the value of the environmental 

and social benefits of a designated water use is often not 

easy. The process of identifying the (I) water quality 

needed at any given time to support the designated use and 

(2) costs of attaining this water quality is complicated. 

This complexity is due in part to the limits of present 

scientific understanding and the intricacy of ecological 

relationships. Consequently, it is very difficult to set 

optimal WQS. 

The following chapters discuss in more detail the 

relationship between WQS and AWT. Chapter 2 explains why 

AWT may not always be necessary to prevent WQS violations. 

In that chapter we discuss the scientific basis for some 

water quality criteria. We point out that unless strong 

scientific evidence is available, the criteria may not be 

significant to water quality. Thus, funds may be spent 

to prevent insignificant violations with no appreciable 

improvements to water quality or public health. Chapter 

3 discusses how modeling predicts what happens to water 

quality when pollution loads change and how modeling may 

be used to predict the need for AWT. Chapter 4 discusses 

the high costs of AWT and the extent to which EPA allows 

cost considerations to enter into the use designation 

process. In chapter 5 we evaluate the significance of a 

number of AWT projects being approved by EPA. For some 

AWT projects, the Appropriations Conference Committee restricted funding to those that will significantly improve 

the environment and public health. 
SCOPE OF REVIEW 

We made our review at EPA'headquarters, Washington, 

D.C.; EPA regional offices in Seattle, Washington; Kansas 

City, Missouri; Chicago, Illinois; Dallas, Texas; Boston, 

Massachusetts; Atlanta, Georgia; and at State agencies 

responsible for water quality in Washington, Oregon, Iowa, 

Kansas, Ohio, Oklahoma, Michigan, Alabama, Wisconsin, 

Illinois, Massachusetts, and Minnesota. The locations were 

selected to obtain broad geographical coverage of States 

for which AWT projects had been approved by EPA. We reviewed 

pertinent documents, interviewed various officials and consulted experts in the areas of WQS and AWT. 

As of September 30, 1979, about $28 billion has been 

appropriated and $24 billion obligated to construct publicly 

owned waste treatment works. EPA estimates that $1.5 billion 

applies to AWT. EPA and the States have placed a high 

priority on constructing such facilities if needed to meet 

WQS. In many cases these ,facilities will provide AWT that 

is much more expensive than secondary treatment. 

We visited nine AWT projects awarded in fiscal year 

1979; reviewed documents; and discussed these projects with 

local officials, design engineers, and other interested 

parties. The nine projects visited were selected because 

they represented the first projects awarded in fiscal 

year 1979. 

The Appropriations Conference Committee has required 

the EPA Administrator to personally ensure that Federal 

funds for fiscal year 1979 be used for-projects providing 

treatment beyond secondary only if the projects would 

significantly benefit the public health and improve water 

quality. Four of the projects we visited were reviewed by 

EPA regional offices. 

We looked at 11 projects to evaluate the use of models 

the Administrator reviewed before approving treatment beyond 

secondary. These 11 projects were the first projects considered in EPA's revised review process. Five of the 

projects were approved as proposed, but six had portions 

disapproved. We evaluated these projects solely to 

determine if the modeling.was reliable. We did not 

review the Administrator's decisionmaking process. 

We concentrated our review on AWT for municipal sewage 

treatment plants and did not consider AWT for industrial 

dischargers. However, we believe that the analysis used to 

justify effluent limits for industrial dischargers may have 

the same problems we identified for municipal dischargers, 

as shown in the following chapters. 

3 
We discussed our work with the EPA's internal audit 

group I reviewed relevant internal audit reports, and reached 

agreement on any followup action required in connection with 

our findings. According to an EPA internal audit official, 

only a very small portion of the group's work is related 

to program results-type reviews and no work has been done 

on the significance of WQS violations. 

We reviewed the steps leading to AWT because AWT is 

so costly. According to EPA, about $10 billion will be 

needed by the year 2000 for additional treatment at some 

facilities. WQS may determine the need for treatment 

beyond secondary. 

During the review we were assisted by Dr. Donald T. 

Lauria, Professor of Water Resources Engineering at the 

University of North Carolina, and by Mr. Jerome Horowitz, 

private consultant on water quality and pollution control. 

We reviewed water quality studies by groups such as the 

National Academy of Sciences and the National Academy 

of Engineers, EPA's Environmental Research Laboratory in 

Duluth, Minnesota, the American Fisheries Society and other 

similar research oriented organizations. We also discussed 

water quality matters with individuals recognized as being 

experts in such fields as water quality and mathematical 

modeling. 

To demonstrate that WQS may not be applicable in all 

instances, we drew from studies used by EPA and the National 

Academy of Sciences in establishing the basis for such standards. We also provide comments from various officials and 

experts that support this position. 
CHAPTER 2 

MANY WATER QUALITY STANDARD 

VIOLATIONS‘MAY NOT BE SIGNIFICANT 

Violation of a WQS does not necessarily mean that 

significant environmental damage has been done. WQS 

violations vary widely in their ecological 1/ effects; 

some violations may have virtually no ecolo?jical impact. 

Violations also vary greatly in their social significance, 

depending on the value of the water body and its aquatic 

life to society. 

The following discussion is not intended to show that 

WQS are erroneous, but that much uncertainty exists in 

the WQS-setting process. 

VIOLATIONS MAY BE 

ECOLOGICALLY INSIGNIFICANT 

The ecological significance of violating WQS is 

neither precise nor certain. Scientific information on how 

all species respond to different levels of pollution is 

simply not available. WQS violations which may be dangerous 

to some types of aquatic life may cause little damage to 

others. In fact, standards are generally designed to protect 

the more sensitive (and presumably more valuable) species, 

which may be a small fraction of the total aquatic life 

in a body of water. The significance of a violation also 

varies with its frequency, duration, intensity, and extent. 

The scientific basis for some 

standards is questionable 2,' 

The biological significance of a WQS violation depends, 

in part, on whether scientific evidence shows that a certain 

A/The interrelationship of aquatic organisms and their 

environments. 

2/A large portion of the scientific information cited - throughout this chapter was obtained from EPA's 

"Quality Criteria for Water - 1976" and "Water Quality 

Criteria - 1972," prepared by the National Academy of 

Sciences for EPA. 

5 
level of water quality is needed to protect aquatic life. 

Unfortunately, not enough scientific knowledge is available 

to eliminate uncertainty in setting standards. EPA.describes 

its criteria as "scientific judgments" based on limited 

experimental investigation and has warned that they should 

be used with considerable judgment. 

The data to quantify the fishable/swimmable goal in 

a scientifically sound manner is still rather limited. The 

ideal data base for criteria development would include information on a large percentage of aquatic species and would show 

the response to a range of concentrations for various factors 

(DO, ammonia, pH, phosphorus) over a long period. But this 

data is not available. Investigators are only now beginning 

to derive such data for a few water constituents. The 

effects of any substance on more than a few of the vast 

number of aquatic organisms have not been investigated. 

The opinions of competent scientists conflict on the 

degree to which various characteristics--even common ones-- 

affect aquatic life. Test results vary widely for the same 

fish species, similar conditions, and the same toxic material. 

The Director of the Illinois Environmental Protection Agency 

has pointed out that the fishable/swimmable goal is a biological objective, but the criteria are physical and chemical 

substitutes. He stated: "TO allege that we have sufficient 

knowledge to make this chemical to biological relationship 

with great specificity is, in my judgment, wrong." 

We reviewed a number of characteristics affecting the 

water quality EPA says is needed for fishing/swimming. 

In particular, we looked at DO and ammonia because these 

characteristics are very important to fish. 

DO criterion lacks 

firm scientific basis 

DO concentrations are important in gaging water quality. 

In fact, DO has been called "probably the single most important water quality parameter in fisheries management." Therefore, a complete and thorough scientific basis for the 

recommended DO criterion would be expected, but cannot be 

found. Scientists disagree considerably on how much DO fish 

need. Most species of adult fish (including brook trout) 

can survive at very low DO concentrations. Minimum tolerable 

levels reported by some investigators are several times 

greater than those reported by others for the same fish 

species, tested at about the same temperatures. Many apparent 

contradictions also exist about the effects of DO levels 

on hatching of fish eggs and growth of many young fish. 
We believe EPA lacked sufficient data to base the DO 

criterion on the needs of specific fish species. EPA, 

however, based its recommended DO criterion on concentrations 

known to permit "the maintenance and well-being of the 

population as a whole." The DO levels for maintaining a 

good t naturally occurring fish population also lack clear-cut 

scientific support. For example, a DO concentration of 4 

milligrams per liter (mg/l), l/ and perhaps much lower, will 

support a varied fish population, including valuable food 

and game species; but one researcher found the greatest 

variety of species at 9 mg/l. Lowering the DO to even 

5 or 6 mg/l can kill some fish or stunt their growth. 

In fact, researchers have pointed out that the rates of 

growth and embryonic development and the activity of fish 

can be limited by the supply of oxygen even when DO concentrations are near or above saturation levels. 

According to "Water Quality Criteria - 1972" (prepared 

by the National Academy of Sciences and the National Academy 

of Engineering): 

"Any reduction of dissolved oxygen can reduce the 

efficiency of oxygen uptake by aquatic animals and 

hence reduce their ability to meet demands of their 

environment. There is evidently no concentration 

level or percentage of saturation to which the oxygen 

content of natural waters can be reduced without 

causing or risking some adverse effects on the 

reproduction, growth, and consequently the production of fishes inhabiting those waters * * *Ir Any 

reduction in oxygen may be harmful by affecting fish 

production and the potential yield of a fishery." 

EPA headquarters has recommended a minimum DO level of 5 mg/l 

(not a daily average). Because DO levels may fluctuate 

during a 24-hour period, achieving a minimum of 5 mg/l 

requires a higher level of DO (for example, 6 mg/l) as a 

daily average. However, at least two EPA regions have 

recommended minimums of 4 mg/l and daily averages of 5 mg/l. 

The choice of a DO criterion has a significant economic 

impact. For example, Ohio officials told us that raising 

the average DO from 5 to 6 mg/l will cost about $76 million 

per year in Ohio alone. Ohio officials believe an average 

of 5 mg/l DO at the 7-day, lo-year low flow (occurring only 

L/Equivalent to parts per million (assuming unit density). 

7 
0.2 percent of the time) is more than adequate to protect 

Ohio's aquatic life. 

Ammonia criteria al,so have 

inadequate scientific basis 

Ammonia is another water quality factor for which 

the EPA-recommended criterion lacks a clear-cut scientific 

basis. For example: 

--Extensive research on ammonia toxicity has shown 

many different results for different species under 

different test conditions, and some research 

results are contradictory. A committee of the 

American Fisheries Society concluded that EPA has 

not shown that its recommended criterion is appropriate for most freshwater fish. The State of 

Ohio has determined that a higher level could 

be used for warmwater species, and the State of 

Iowa has set different criteria for warmwater and 

coldwater species and for winter and summer 

conditions. 

--Various researchers reported toxic levels ranging 

from 0.2 to 2 mg/l of un-ionized ammonia. On 

the otherhand, EPA recommended a criterion of 

0.02 mg/l to protect life forms for which no 

research was available. EPA's "Quality Criteria 

for Water-1976" provided no scientific basis for 

this safety factor, and the Director of EPA's 

Environmental Research Laboratory (Duluth, Minn.) 

recently conceded that EPA's recommended criterion 

appears to be too conservative for many streams. 

The ammonia criterion selected by a State can have 

quite an impact on sewage treatment costs. AWT may reduce 

the ammonia in sewage co meet the WQS for ammonia. However, 

much of this treatment may not be useful because violating 

the standards may have no biological significance. 

Other important factors have 

little scientific foundation 

Another important water quality characteristic is pH (a 

measure of acidity), which affects the toxicity of many compounds. Again, we found no clear-cut scientific support for 

the EPA-recommended criteria for freshwater fish. According 

to the European Inland Fisheries Advisory Commission, there 

is no definite pH range within which a fishery is unharmed and 

outside which it is damaged; rather, it deteriorates gradually 

8 
as pH values move further away from the normal range. At 

some levels of pH, various species of aquatic life thrive but 

others do poorly. 

Bacteria levels are considered important for swimmable 

waters, and EPA has recommended levels of fecal coliform 

bacteria that should not be exceeded for swimmable waters. 

However, epidemiological studies have not determined that the 

bacterial levels in bathing w&ers relate to illness in swimmers. In fact, a cause-and-effect relationship is 

questionable at the bacterial levels typically found in 

U.S. waters today. 

EPA has recommended other specific criteria to protect 

waters used for domestic water supply from pollutant levels 

that could cause public health problems. Like other criteria 

recommended by EPA, these have limited scientific support and 

are very conservative. For example: 

--EPA set a criterion of 50 ug/l (micrograms 

per liter) for total chromium, although 

symptoms of excessive dietary intake are 

unknown, and a family is known to have drunk 

water for 3 years at a level of 450 uq/l (9 

times EPA's recommended criterion) without 

known ill effects. 

-EPA recommended a mercury criterion of 2 

us/l l "Water Quality Criteria-1972" also 

recommended this criterion, in the belief 

that mercury intake from all sources should 

be limited to 30 ug/day. The lowest continuous exposure associated with toxic symptoms, 

however, is approximately 300 ug/day of the 

most toxic form of mercury for a person of 

average weight (154 pounds). 

The quality criteria for domestic water supplies are 

made even more conservative by assuming that the drinking 

water treatment process will remove none of the toxics for 

which the criteria are set. The degree to which toxic 

substances are removed by the drinking water treatment process (sedimentation, filtration, and chlorination) is 

generally not known. Some. toxic substances, however, are 

known to be associated with suspended solids in raw surface 

waters and may be removed, at least to some extent, by 

treatment. 

EPA officials informed us that EPA is making some of its 

criteria less conservative. For example, EPA has published 

drafts of criteria for 65 toxic pollutants. The methodology 

9 
used to derive aquatic life criteria departs from the 

traditional practice of protecting the most sensitive species 

tested and instead introduces statistical techniques designed 

to be 95 percent protective. EPA officials also informed us 

that EPA intends to update all its criteria periodically to 

keep them scientifically current. 

General standards do not fit 

all waters at all times of yea? 

The biological significance of a WQS violation depends 

on how the general criteria fit the specific water body and 

the time of year when the violation occurs. Five basic 

factors may make a violation relatively unimportant in a 

specific body of water at a specific time of year. 

Local aquatic species 

The general standard may not fit the local aquatic 

community. Aquatic species vary greatly in sensitivity, and 

EPA-recommended criteria are set to protect the more sensitive species (for example, trout). If these species are not 

present in a body of water, a WQS violation may be without 

biological significance. In waters across the United States, 

some 500 native freshwater fish dwell. Each tends to live in 

a certain environment. For example, sturgeon are not found 

in a trout stream. Habitat is affected by more than just 

water quality. These environments are named according to the 

species that inhabit them: 

--The trout stream is usually in forested mountains near 

the source. The water is swift and clear; it cascades 

and tumbles; and the bottom is stoney. The stream is 

almost completely shaded by trees, which keeps its 

waters cold enough for trout to survive. 

--The bass stream lies downhill from the trout fishery. 

Its water is somewhat slower and warmer; more than 

three-quarters of the water is in sunlight. Some 30 

percent of the surface is made up of calm eddies and 

pools. Less oxygen is dissolved in this water, but a 

greater variety of fish have adapted to it. 

--The minnow stream. is too small and warm to support 

trout and too small to support significant numbers of 

smallmouth bass or other warmwater game fish. The 

stream supports primarily forage fish (such as darters, 

minnows, and shiners). 

--The sturgeon river has waters which are deep, warm, 

and slower than the trout and bass streams. Most of 

10 
the river is in sunlight, and the warmth supports much 

more life than the bass stream. Sturgeon, catfish, 

carp, and rock bass live in these rivers. 

-- The lake trout lake is dominated by lake trout and 

whitefish. Older lakes and those farther south, however, may feature rough fish such as perch, bullheads, 

and carp. 

Natural levels of local pollutants 

Local violations of general WQS may result from natural 

sources. Levels of pollutants from these sources vary substantially from one water body to the next, which makes it 

difficult to achieve standards consistently. Although natural 

levels of pollutants may have significant adverse effects, 

i,ncluding fishkills, they may be part of the normal ecology 

and not significant enough to warrant corrective action. 

Some States hedge their standards to ignore violations 

from natural causes. According to Washington and Kansas 

officials, WQS violations are, in effect, ignored when the 

cause is believed to be natural. In many States, WQS 

are widely violated by natural conditions without much 

regard. Extreme natural conditions affect the more common 

water quality characteristics. For example: 

--Some waters have naturally low oxygen content-- 

some so low that fish cannot live in them during 

a large part of the year. However, tidal marshes 

in Louisiana have low DO throughout the summer 

but support a thriving fishery. 

--Natural stream erosion and snow melt during 

periods of high flow cause violations of 

criteria for suspended solids and turbidity 

(muddiness). 

--Many temperature standards are violated by common 

natural conditions (e.g., summer heat). 

Toxicity-reducing characteristics 

of local water 

The toxicity of a pollutant may be so greatly reduced 

by the characteristics of local waters that a WQS violation 

has no significant biological effect. For example: 

--Heavy metals such as cadmium, lead, copper, or zinc may 

be considerably less toxic in hard water. Cyanide and 

hydrogen sulfide are less toxic in waters with high pH. 

11 
--Various instream conditions may reduce ammonia's 

toxicity. 

Form of the pollutant 

The form in which a pollutant occurs may have a 

significant biological impact. For example: 

--According to an EPA official, criteria for heavy metals 

are based on laboratory tests using the pure form of 

the metal. He said that in actual streams these metals 

generally are present in less potent forms. According 

to a sanitary engineer, because only soluble metals are 

toxic, many streams have good fish stocks in spite of 

violating standards for total forms of various metals. 

--Certain forms of cyanide are much less toxic than 

others. EPA recommended a criterion of 5 ug/l total 

cyanide to protect aquatic life and wildlife. But, 

according to an environmental consultant, only free 

cyanide has been shown to be toxic to fish at concentrations less than 1,000 ug/l. The National Academy, 

of Sciences' "Water Quality Criteria-1972" recommended 

5 ug/l free (not total) cyanide. On July 25, 1979, 

EPA proposed to replace its recommended total cyanide 

criterion with one stated in terms of free cyanide. 

According to EPA officials, however, relatively small 

amounts of complexed cyanide can quickly generate 

enough free cyanide to violate this criterion 

if the water in question is moderately clear and 

is exposed to sunlight. 

--Phenols are a large class of compounds. Many 

phenols are toxic, and many of them give fish an 

unpleasant taste. Except in the case of chlorophenols, a committee of the American Fisheries 

Society found no justification for the EPA recommendation of 1 ug/l. Phenol concentrations 10 to 25 

times qreater than EPA's criterion commonly occur 

in Iowa's waters and have caused no problems. On 

July 25, 1979, EPA proposed changing the phenol 

criterion for protection of freshwater aquatic 

life to 600 ug/l as a 24-hour average and 3,400 

ug/l as a maximum never to be exceeded. 

--Turbidity criteria are often violated. Although 

turbidity reflects the amount of sediment being 

carried in the water, EPA officials told us that 

only a rough relationship exists between turbidity 

and the damage to fish habitat and spawning done 

12 
by sedimentation. They said that the damage depends 

on the size of the sediment particles in a 

particular stream at a particular time. 

S-Fecal coliform (bacteria) standards set to protect 

swimming waters-are also-frequently violated. However, 

the violation is significant only if bacteria that 

cause disease in humans are present. An EPA official 

told us that many violations--perhaps most--are caused 

by nonpoint source pollution, much of which is from 

nonhuman sources (for example, drainage from pasture 

lands). He told us there is little danger of disease 

transmission from such a nonhuman source. 

According to EPA officials, many water quality 

characteristics influence a constituent's toxicity, but sufficient data was available to include only the effects of 

hardness on metals toxicity. While other characteristics (for 

example, pH) also affect toxicity, not enough quantitative 

data was available to include them in developing water quality 

criteria. 

EPA officials further added that the form of a metal does 

affect toxicity; insoluble forms usually, but not always, are 

less toxic than soluble forms. The practical difficulty is 

that metals can shuttle back and forth between soluble and 

insoluble forms as the water chemistry changes. EPA argues 

that it may be practically impossible to predict changes 

in water chemistry and shifts in metal solubility. Therefore, 

EPA has chosen to express water quality criteria in terms 

of total metal. L 

Time of year 

The time of year when a WQS violation occurs may affect 

the violation's significance. According to numerous experts, 

violations of bacterial standards set for swimming waters 

usually have no significance during the cold winter months. 

Water quality criteria are generally set to protect 

the most sensitive life stages of aquatic organisms, such 

as spawning and migration. When such activities are not 

occurring, or in streams stocked with fish propagated elsewhere, violations of such standards may not be biologically 

significant. 

13 
Some violations may not 

cause problems 

The biological significance of a WQS violation depends 

on the nature of the violation itself--its intensity, duration, frequency, and extent. In other words, a brief, 

occasional, and slight violation in a small portion of 

a water body is generally not as serious as a sudden, 

intense violation over a major part of the water body. A 

particular violation, therefore, may have no significant 

biological effect. 

The longer a potentially lethal concentration lasts, 

the more fish may die as a result. Even when the concentration is not potentially lethal, duration and frequency 

are important in determining biological significance. 

EPA-recommended water quality criteria are set at 

levels to protect aquatic populations from long-term effects 

on reproduction, growth, and level of activity. These 

criteria presume continuous exposure. Higher concentrations 

may be reached occasionally, but briefly, for many pollutants 

without causing damage. For example, changes in instream 

ammonia levels, as well as movement of fish into and out 

of ammonia-enriched waters, affect the exposure time 

and consequently the effects on aquatic life. According 

to an environmental consultant, large numbers of small, 

sensitive fish have been known to concentrate just downstream from a fish hatchery where the ammonia level was more 

than 11 times higher than the EPA-recommended criterion 

(based on continuous exposure); further downstream, where 

ammonia levels were much lower, fewer fish were found. 

EPA is now recognizing the importance of duration in 

assessing the significance of a violation. Although water 

quality criteria are generally regarded as limits never to 

be violated, no matter how briefly or slightly, EPA in 

May 1978 proposed the concept of a twofold criterion-- 

an instantaneous maximum and a 24-hour average. In estimating the costs of controlling combined sewer overflows for 

its 1978 Needs Survey, EPA recognized that duration was 

important and used the following criteria for DO: 

"The minimum receiving water dissolved oxygen 

concentration shall*not average less than 2.0 

my/l for more than 4 consecutive hours; nor 

shall the minimum receiving water dissolved 

oxygen concentration average less than 3.0 mg/l 

for more than 72 consecutive hours (3 days). 

In addition, the annual average receiving water 

14 
dissolved oxygen concentration shall be greater 

than 5.0 mg/l for all waters which will support 

warm water species and shall be greater than 

6.0 mg/l for all waters which will support coLd 

water species." 

The extent of a violation may also be an important factor 

in determining its biological significance. Violations in 

only a portion of a water body may not be highly significant. 

EPA's mixing zone l/ guidance recognizes that limited areas 

of degradation are-less significant. This guidance permits 

a State to allow poorer water quality (within certain concentration limits) in a limited zone near a source of pollution, 

as long as a zone of passage for migrating fish and other 

organisms is protected and certain other conditions are met. 

VIOLATIONS MAY BE . 

SOCIALLY INSIGNIFICANT 

The environmental significance of WQS violations may 

also depend on the social significance of the water body. 

The social significance is determined by 

--the extent to which a water body is valuable to 

someone for commercial or recreational purposes and 

--the availability of other water bodies providing a 

similar use. 

Some natural waters are 

of little value to society 

The significance of violations varies with the water 

body's commercial or recreational usefulness to society. 

This usefulness depends on the degree to which a water 

body supports desired activities (such as fishing and 

swimming) and on its accessibility to those who want to 

use it. 

Waters vary naturally in the amounts and kinds of fish 

they support. The population of aquatic life naturally 

found in one water body may be of a higher or lower value 

than another water body. In particular, waters differ in 

their ability to support game and pan fish, which are more 

desirable for human use. 

l/A zone of initial dilution in the immediate area of a - 

point or nonpoint source of pollution. 

15 
Many natural factors affect the kind of quality of 

fish supported. Some waters naturally support substantial 

populations of trout or bass; others support primarily forage 

fish such as minnows or rough fish such as carp. Some water 

bodies (such as salt lakes) do not support any significant 

fish life. Some streams are essentially dry ditches (except 

when it rains) and are often useless as far as aquatic life 

is concerned. Other intermittent streams, however, may have 

deep holes that can sustain fish during long droughts. Some 

streams are at times fully diverted for irrigation; others, 

according to a Washington State official, are no more than 

artificial channels for returning irrigation waters. Even 

high-quality streams may be of limited value for fishing; 

Washington State officials told us that many high mountain 

streams are virtually without resident fisheries and that 

many naturally go dry during part of the summer. 

Waters also vary in attractiveness to swimmers. Some 

streams are simply too dangerous for swimming because of 

waterfalls, rapids, and dangerous currents. Others discourage swimming because they are shallow, muddy, or cold. 

Many streams dry up or nearly dry up in summer. New York 

alone has over 3,000 intermittent streams that generally 

cannot support swimming in the summer. Streams composed 

of treated sewage (no matter how well treated) may discourage swimming for esthetic reasons despite their pleasant 

appearance and acceptably low bacterial concentrations. 

The usefulness of a water body for swimming or fishing 

also depends on its accessibility. Social usefulness and 

the significance of WQS violations are reduced by inaccessibility. Some streams are almost inaccessible because of 

canyons, steep slopes, or other physical barriers. Others 

have no public access and some can be reached only by 

a few hikers. Many are in low-population areas and receive 

little use. Kansas WQS recognize the significance of 

accessibility. Kansas has strict limits on coliform bacteria 

only where public swimming facilities are maintained. 

Siqnificance of violations is reduced if 

other high-quality waters are available 

The significance of a violation also varies with the 

degree to which the water-use in question is readily available in other nearby bodies of water. A violation that 

limits the use of a specific water body for swimming or 

fishing has less significance when it is located near other 

swimming and fishing waters. In the State of Washington, 

for example, State officials told us of a lake maintained 
by wastewater flows. They said that nutrients in the sewage 

promoted algae and weeds, which interfered with swimming. 

However, the lake is an excellent fishery. According to these 

officials, to make the water swimmable would.require AWT (or 

land disposal, which would be more cost effective but would 

dry up the lake). They said that because a nearby lake is 

available for swimming, this lake is maintained solely for 

fishing. 
CHAPTER 3 

PREDICTING WATER QUALITY VIOLATIONS 

BY USING MATHEMATICAL MODELS 

IS VERY UNCERTAIN 

AWT is usually justified on the basis of predictions 

that without it WQS will be violated, at least during 

summer droughts. These predictions, which are based 

on mathematical modeling, may be made in the absence 

of existing violations or before secondary treatment 

is installed. We found, however, that current water 

quality modeling is often unreliable--too unreliable 

to be used as the only justification for constructing 

treatment facilities beyond secondary. 

Mathematical modeling is very important for properly 

predicting or estimating the level of treatment needed. 

Modeling may be the only way to estimate the level of 

treatment needed when there are no discharges from sewage 

plants in the area or when determining the specific treatment level needed beyond secondary. We believe modeling 

has a place in making cost-effective environmental 

decisions. However, our review indicates that substantial 

improvement is needed. 

Many of nature's processes are still not known well 

enough to justify AWT through modeling. Mathematical models 

that simulate DO levels in water are often difficult to 

prepare. Often extensive information is needed and a great 

deal of analysis is necessary to simulate a stream's 

complex natural processes. 

Many streams cannot be modeled; some, because 

essential information is not available. However, EPA 

believes that: 

"While models currently in use do not attempt to 

represent each and every process within an aquatic 

system, those major processes that are significant 

and relevant to the [AWTI decision are adequately 

represented by those models." 

We observed that modeling is poorly done in many 

instances. Principal problems include 

--neglecting or not fully understanding the impact 

of nonpoint sources on water quality, 

18 
--using unreliable or inadequate water quality 

data, and 

--failing to determine the model's predictive 

reliability. 

Some decisionmakers responsible for funding projects 

for treatment beyond secondary seem to know that modeling 

results are often imprecise. In some situations where 

modeling results are suspected of being imprecise, decisions 

are made to (1) construct less sophisticated facilities 

than a model may specify, (2) phase in construction for 

the AWT portions of new sewage treatment plants, and (3) 

require stream surveys to assure reliable water quality 

information. 

MODELING IS A COMPLICATED PROCESS 

The Clean Water Act requires that sewage treatment 

plants must provide at least secondary treatment. In 

many instances modeling is used to predict how much 

additional treatment is needed beyond secondary. Modeling 

predicts the amount of pollution that can be allowed without 

violating WQS. Modeling involves the calculation of total 

maximum daily loads of pollutants. The act explicitly 

requires a margin of safety in the calculation of total 

maximum daily loads to account for any lack of knowledge 

about effects on water quality. These calculated loads 

are then distributed among the point and nonpoint sources 

of pollution through a process known as wasteload allocation. 

The allocations are translated into pollution control 

requirements through discharge permits, which set forth 

the effluent limits that govern the design and operation 

of treatment plants. 

Mathematical models aid decisionmakers in ensuring that 

pollutant discharges will not violate WQS. EPA estimated 

that $10 million is spent annually on developing mathematical 

models and special intensive stream surveys to obtain the data 

required for modeling. 

We discussed modeling problems with water quality 

experts at the local, State, and Federal levels and reviewed 

literature on mathematical modeling. We asked a member 

of EPA's AWT Task Force A/ to provide additional modeling 

i/This task force is responsible for reviewing all projects 

with incremental costs for treatment beyond secondary in 

excess of $1 million. (See ch. 5.) 

19 
information on 11 projects costing $202.1 million which 

have incremental costs for treatment above secondary of $46.1 

million. (See app. I.) EPA shares our belief that these projects reflect the quality of modelinq work currently used to 

justify AWT. EPA agrees that models have been misused in the 

development of wasteload allocations and effluent limitations. 

However, it says that most of the shortcomings have been 

identified and remedial actions are being taken. 

DO models for streams are among the simplest mathematical 

models for estimatinq maximum daily pollution loads. The most 

common models deal with only the DO component of water quality. 

These models evaluate a stream's DO levels and the impact of 

.various levels of pollutant discharges on future DO levels. 

According to EPA officials, DO models have been researched 

since the 1920s and are the most reliable type of model. We 

concentrated our review on stream models of DO rather than on 

models dealing with DO in lakes, reservoirs, and estuaries, 

which are much more complex. Although it is recognized that 

DO is just one component of water quality, other components 

(such as toxic substances and nutrients) are usually iqnored 

in the most common models. 

Models currently in use vary from simple "desk-top" 

types to hiahly complex ones requiring a large computer to 

perform the calculations. Simple or complex, all the models 

for DO serve one common purpose --to predict whether supplies 

of DO will be adequate during drought conditions once the 

treatment plants are built. 

An adequate supply of DO is important for two reasons: 

--Aquatic organisms must utilize oxygen that has been 

dissolved in the water. Wherever it is important to 

protect a stream’s fishery. it is also important to 

protect the fishery's oxygen supply. 

--When waters lose all oxygen they often smell foul 

and become septic. To protect the public, AWT must 

ensure that streams never lose all DO. 

Modelers must consider major factors 

that are hard to determine 

DO models keep track'of a stream's oxygen supplies like 

an accountant; they add the DO "income" and subtract the DO 

"expenditures." Streams obtain oxygen from three major 

sources: 

20 
--From oxygen already present in the water from other 

sources. 

--From the atmosphere by a process called atmospheric 

reaeration. Water tumblinq over rocks picks up much 

more oxygen from the atmosphere than water lying in 

deep, still pools. When ice covers the water in a 

solid sheet, air is blocked off and generally the water 

does not get oxygen from the atmosphere. 

--From algae and other aquatic'plants by a process 

called biological reaeration. In sunlight plants 

produce oxygen and add it to the water. At night 

the plants breathe oxygen. thereby removing it from 

the water. 

Streams lose oxygen in three major ways: 

--By oxidation of materials carried in the water. 

As these materials decompose, they withdraw oxygen 

from the water. Most models distinguish between two 

kinds of oxidative decomposition: carbonaceous lJ 

oxygen demand and nitrogenous 2/ oxygen demand. 

--By decomposing muck in the streambed, a process called 

benthic or sediment oxygen demand. 

--By nighttime loss of oxygen to plants living in the 

water. 

These six broad classes of oxygen income and expenditure 

are not fixed constants: thev are highly variable rates. 

Like some kinds of rates, they are a function of time. When 

the oxygen income rate is fast and the oxygen expenditure rate 

is slow, the stream will soon have a high net oxygen balance, 

even if its starting balance was zero. Conversely, when a 

stream expends oxygen more rapidly than its oxygen income 

allows, it will eventually have a small net oxygen balance. 

The net balance depends on how high the rates are and how long 

they last. A short burst of high expenditure may do little 

harm to the net oxygen balance, but a long spell of low 

L/Readily oxidizable organic matter that is effectively 

removed by secondarv treatment. 

z/Organic matter that is difficult to oxidize and is removed 

by the AWT process of nitrification. 

21 
expenditure may use up all the oxygen if the income 'is low. 

Because the factors affecting DO levels in water are hard to 

determine, the precision of a model depends to a large extent 

on how well these factors are determined. 

Biochemical oxygen demand 

and ammonia measurements 

require painstaking analysis 

DO models require projections or data about biochemical 

oxygen demand (BOD) and ammonia discharges, two very important 

factors in oxygen consumption. BOD and ammonia measurements 

allow the computation of the ultimate oxygen demand. These 

are not easy measurements to make and require painstaking 

effort. 

One common measure of the amount of oxygen-demanding 

substances in a river is biochemical oxygen demand. When BOD 

is carefully measured, analysts keep track of how much DO is 

lost from the water day by day, usually for 5 days; if necessary, they keep track for longer periods, such as 30 days. 

Careful workers take pains to specify the kind of BOD: 

the l-day BOD (the amount of DO consumed during 1 day), the 

5-day BOD, the 20-day BOD, and so forth. BOD also depends on 

temperature; at higher temperatures BOD is generally higher, 

and at lower temperatures it is generally lower. 

Temperature and time are two of the most important 

factors affecting BOD, but others may also be important. For 

example, many kinds of-metals dramatically lower BOD; tiny 

traces of copper may cut the BOD in half. Whenever something 

is done to reduce metal concentrations in a stream, BOD is 

likely to increase sharply. Most laboratories measure 

BOD at 20° C for 5 days, often diluting the samples with 

distilled water (rather than with river water, which may 

contain trace metals and other oxidation inhibitors). 

Some laboratories add bacteria to BOD samples; others 

do not. Each of these procedures may give a different 

value for BOD, which may cause considerable error or uncertainty when the values are used in developing mathematical 

models. 

Ammonia may also reduce oxygen in a stream. When 

water contains oxygen, ammonia, and certain kinds of bacteria, 

the ammonia is oxidized. As ammonia is oxidized, it removes 

oxygen from the water, thereby lowering the DO. Shallow 

streams tumbling over a rocky streambed generally lose 

ammonia quickly, but deep, sluggish streams generally 

lose it very slowly. 

22 
Modelers must decide how to deal with ammonia oxidation 

throughout a stream. Wherever the stream is shallow and 

rocky, the modeler may be justified in selecting a high 

oxidation rate. Where the stream is deep and, sluggish, 

the modeler may select a rate near zero. Because the 

physical characteristics of a stream vary, the oxidation 

rate should also vary to predict DO consumption accurately. 

Without detailed analyses of ammonia and its impact on DO 

throughout the stream, the modeler cannot vary the rate and 

therefore has to guess what is going on. For example, a U.S. 

Geological Survey (USGS) representative said that ammonia 

oxidation rates for the Willamette River study changed from 

place to place, depending on whether the water was shallow 

or deep. In shallow waters the ammonia oxidation rates were 

higher than in deeper waters. 

Even when a shallow, rocky stream contains ammonia, 

oxygen, and the right kind of bacteria, it does not follow 

that all the ammonia will be oxidized. Some of the ammonia 

may be bound onto metal ions or clay particles, a process 

which removes ammonia from solution without decreasing the 

DO. Ammonia is also an excellent plant food. If the water 

is full of algae and other aquatic plants, they may remove 

the ammonia without decreasing DO. All these factors 

must be accurately accounted for and carefully measured 

or estimated before DO levels can be realistically modeled. 

MANY WATER QUALITY PROCESSES 

CANNOT BE ACCURATELY MODELED 

It is very difficult to model the complex natural 

processes found in many water bodies because so little is 

known about them. The legislative history of the Clean 

Water Act pointed out how many States were struggling 

to identify the complex relationships between pollutants 

and water use. The task is arduous. The state of the 

art for simulating the effects of nutrient loads does 

not allow precise prediction. Predicting the effect 

of future pollutant loads on future water quality adds 

to the complexity and uncertainty of model results. 

One EPA modeler stressed that modeling aquatic relationships 

is far less certain than trying to simulate physical 

relationships such as the trajectory of a rocket. This 

modeler said biological relationships such as those in 

a stream are not precisely known now and may never be, 

regardless of the amount of effort put into modeling. 

23 
The modeler tries to estimate what will happen 

to water quality if some variab1e.s are changed, but some 

problems can prevent the estimates from being accurate. 

These problems are that: 

--Little is known about the complex natural 

processes of water bodies. 

--In many cases existing methods for estimating 

stream reaeration are not applied properly. 

--Water quality data is frequently subject to 

measurement errors or is not available. 

EPA agrees that nutrient modeling is still 

highly uncertain and that it is extremely difficult to 

develop a sound basis for selecting AWT processes for 

removing nitrogen and phosphorus. However, EPA.officials 

believe that despite the uncertainties identified in this 

report, the state-of-the-art of DO modeling is sufficiently 

developed for decisionmakers to use in determining needed 

levels of treatment. 

Methods for estimating stream 

reaeration and oxyqen production 

are subiect to substantial variation 

The rate of transfer of oxygen into water from the 

atmosphere (reaeration) and from algae and other aquatic 

plants (photosynthesis) is very difficult to measure. 

The reaeration rate is one of the most important factors 

in DO models because it determines the oxygen income of the 

stream. However, many methods of estimating reaeration give 

substantially different results. 

Many kinds of equations for estimating reaeration are 

in widespread use. USGS is now preparing an analysis of 

these equations because several studies comparing the various 

methods showed big differences. USGS applied six of the most 

respected predictive equations to a stream that had been 

carefully measured and found the following: 

--Results from the six equations for any given set of 

hydrologic conditions differed substantially. Differences of 1,000 percent or more were not uncommon. 

--For any given data set, the relationships between 

streamflow and estimated rates of reaeration may be 

quite different. Some estimates showed that reaeration 

24 
increased with the rate of flow, but others showed 

that it decreased. 

--No one method consistently gave results above 

(or below) those of another method. 

Wisconsin Department of Natural Resources staff 

performed a similar analysis to help select the best 

reaeration equations. The staff measured reaeration rates 

using gas tracers, then compared the measurements with 

estimated reaeration rates for selected streams using 

20 different equations. These comparisons emphasized 

the problems inherent in estimating reaeration. The average 

error rate for the five best estimating equations ranged 

from 23.8 percent to 40.1 percent of measured reaeration 

rates. The remaining 15 equations varied in error rate 

from 41.6 percent to over 200 percent. 

Estimating a stream's oxygen production is especially 

complicated when algae or other aquatic plants grow in the 

water. The modeler must accurately estimate how much oxygen 

is produced during daylight hours and how much is removed 

from the water at night. If the modeler assumes that the 

stream will be in drought, (which may occur at any season of 

the year), the oxygen production estimates must be recomputed 

for drought conditions. Further, the modeler must accurately 

estimate how the stream will respond to pollution control 

measures. These complications make it difficult for many 

water quality processes to be modeled accurately. 

Changes in the reaeration formula may greatly affect 

BOD effluent limits. For example, Iowa's reaeration formula 

includes a gas escape coefficient, L/ among other values. 

Our analysis showed that the Harlan, Iowa, effluent limits 

for BOD would change from 10 mg/l to 30 mg/l when the gas 

escape coefficient is changed from 0.048 to 0.115. 

Iowa recently-revised Harlan's BOD effluent limit from 

10 to 30 mg/l. Treatment beyond secondary for BOD is no 

longer required. An Iowa representative said that a major 

reason for the change was an increase in the gas escape 

coefficient from 0.048 to 0.115. Thus, changes in the gas 

escape coefficient can significantly change waste treatment 

requirements. 

J/An estimate of reareation from the atmosphere. 

25 
EPA recognizes the need for caution and judgment in the 

selection and use of methods for estimating reaerati,on 

rates in any given situation. According to EPA officials, 

steps are being taken to provide further guidance on this 

selection process. 

In summary, it is important to accurately estimate the 

assimilation of oxygen into a stream. Although there are 

methods for accurately estimating physical reaeration, they 

are rarely used. Predictions of biological reareation are 

extremely complicated and subject to many sources of error. 

Poor estimates for reaeration can result in justification 

of excessively stringent treatment facilities. 

Water quality data can be 

subject to measurement errors 

The wide range of water sampling techniques and 

laboratory procedures often lead to erroneous data as a 

result of collection errors, faulty lab procedures, and the 

failure to accurately measure characteristics such as BOD. 

Measurement errors, especially in effluents, can invalidate 

even the best models. 

Collection errors 

Obtaining accurate water quality data requires diligence 

and skill. Well-trained teams must be deployed in the field 

to make careful measurements, collect samples for analysis in 

the laboratory, and develop detailed understanding of the 

stream. Lack of attention to detail can be disastrous. For 

example, wherever algae and other aquatic plants are common, 

the field team must make detailed DO measurements around the 

clock because DO during the afternoon may be well above the 

saturation value (called supersaturation) while DO between 

midnight and dawn may approach zero. 

Where plant life is important in the stream being 

surveyed, DO values may vary from quite high in the afternoon to nearly zero after midnight. The Ohio Environmental 

Protection Agency reported instances where DO fluctuated 

within a day from over 5 mg/l to 1 or 2 mg/l. These large 

variations were caused by plants producing oxygen during the 

daytime (photosynthesis) then consuming oxygen at night 

(respiration). Depending on when and where the stream is 

surveyed, DO levels could be nearly anything. In modeling, 

it matters greatly whether DO levels are very high or very 

low. 
Faulty laboratory procedures 

Errors can result in a stream survey from improper 

laboratory procedures. Samples must be properly 

collected, carefully handled, and rushed to a competent 

analytical laboratory. Time is critical because some important tests must be made on very fresh samples. For example, 

BOD tests must begin quickly-- any delay will cause the laboratory to miss the short-term oxygen demand. If samples for 

BOD analysis sit on the shelf for some time before they are 

analyzed, the oxygen demand may be seriously underestimated. 

Wisconsin's Department of Natural Resources recently 

discovered errors in its wasteload allocations because 

nonstandard testing techniques were used for measuring longterm BOD. Papermill companies on the Fox and Wisconsin 

Rivers hired consultants to evaluate the State's modeling. 

The consultants observed that the State used rubber stoppers 

in the bottles used for BOD tests. The rubber allegedly 

absorbed some DO from the sample, thereby distorting the 

BOD values. Representatives from the State and the papermills 

could not specify the significance of the errors, but both 

agreed that the analysis had to be redone. Although the State 

redid the long-term BOD tests for the Fox and Wisconsin 

Rivers, we note that it did not redo the long-term BOD tests 

for several other rivers where treatment beyond secondary 

was required. EPA recently approved funding for one such 

facility in Walworth County, Wisconsin. 

Although it is standard procedure for BOD tests to be 

run in bottles with glass stoppers, Wisconsin's laboratory 

used rubber stoppers for years without anyone noticing. Yet 

this seemingly insignificant detail may have had serious 

consequences for pollution control programs on two of 

Wisconsin's most important rivers. One paper industry 

representative said the rubber stopper controversy substantially delayed the final effluent limits for dischargers on these two rivers. EPA believes that while some may 

use this type of deviation from standard procedures to discredit or raise doubts about the validity of the modeling 

results, the magnitude of error caused by this particular 

mistake was probably insignificant in the overall analysis. 

Inability to measure 

small amounts of BOD 

Uncertainties in measuring small amounts of BOD 

can reduce the reliability of the best models. When 

treatment beyond secondary is at issue, effluent BOD 

can be very low. Paradoxically, very low BOD values are 

27 
especially subject to large measurement error. For example, 

the Illinois Pollution Control Board noted: 

"Measurement of BOD at the 4 mg/L level may be 

expected to have an analytical error of 100 

percent.* * *These errors are over and above 

those caused by improper sample collection and 

laboratory methods not consistent with standard 

procedure. It should be noted that much of the 

sampling and analytical work done in Illinois 

is by small treatment-plant operators with 

limited laboratory experience and frequently 

with outdated or poor-quality equipment." 

Other water quality experts have also stated that BOD 

measurements are often very imprecise. 

MANY MODELS ARE NOT 

PROPERLY APPLIED 

Modelers must evaluate nonpoint source pollution, 

use actual data rather than assumptions, and have some type 

of verification study to determine the model's predictive 

accuracy. In many cases, the models we evaluated did not 

do these things. As a result, it is difficult for decisionmakers to know how much to rely on the modeling results. 

The impact of nonpoint source 

pollution is often overlooked 

Nonpoint source pollution can contribute so much waste 

that water quality cannot be improved significantly, even 

with high levels of sewage treatment. Many of the models 

we evaluated did not separately consider pollution from nonpoint sources, which makes it impossible to determine if 

proposed sewage treatment plants are more sophisticated than 

necessary. In addition, reducing nonpoint source pollution 

may allow water quality goals to be achieved without AWT. 

EPA and the Council on Environmental Quality agree that 

nonpoint source pollution is too serious to be neglected. 

In fact, EPA's May 1976 report to the Congress pointed out 

that 37 of 45 States concluded that some State waters will 

not meet 1983 water quality goals because of nonpoint source 

pollution. The Council on Environmental Quality noted in 

its 1976 report: 

"In many cases, the substantial cost involved in 

going from the 1977 to the 1983 standards may not 

noticeably improve water quality because of the 

small amount of pollution removed from regulated 

28 
point sources compared with pollutant loadings 

from natural sources, unregulated agricultural 

activities, urban stormwater runoff, and other 

nonpoint sources.L' 

The Southeastern Wisconsin Regional Planning Commission 

estimated that by the year 2000 only 240 miles of streams 

and 18 lakes in its area could meet the fishable/swimmable 

goal by controlling point sources. Nonpoint source controls, 

on the other hand, would enable 720 stream-miles and 90 

lakes to meet the goal. With both point and nonpoint controls in place, 1,054 stream-miles and 94 lakes could 

meet the goal. Situations like this point out the need 

for comprehensive information to decide which mix of 

solutions is most cost effective. 

Many of the models we reviewed did not separately 

consider nonpoint sources. Modelers we spoke with generally 

justified this failure by saying they model only low flows 

(summer droughts) when nonpoint source waste is not expected 

to contribute to the stream's problems. Concentrating on 

low flows can mean that modelers do not consider all conditions under which water uses may be adversely affected. 

Further, nonpoint source pollution can still occur 

during low flows. For example, the USGS study of the 

Willamette River in Oregon estimated that nonpoint sources 

during summer stream surveys represented about 45 percent 

of the long-term BOD contributed to the river. This 

Willamette study is considered one of the best intensive 

stream surveys ever done. 

An EPA task force representative informed us that only 1 

of the 11 models the task force reviewed, which we requested 

information on, separately considered nonpoint source 

pollution. 

EPA officials contend that in most cases nonpoint 

sources are not a factor in determining the need for 

advanced treatment. However, EPA recognizes that nonpoint 

sources of pollution are a factor in some situations and 

is considering regulations that will require modelers to 

evaluate the impacts of nonpoint sources on water quality. 

EPA now has guidance stating that non-weather-related, 

nonpoint source wastes (such as from leachates; benthic 

oxygen demands; and background DO, BOD, and ammonia) 

should be considered even in low-flow situations. 

Inadequate data is used 

Many modelers use inadequate data in constructing their 

models. Inadequate data results when estimates or assumptions 

29 
vary from actual stream conditions, when stream surveys are 

not conducted during the most stressful period, when sewage 

flows are not matched to low flows, and when actual 

streamflow data is not used. 

Estimates or assumptions 

sometimes vary from 

actual stream data 

Modelers may use guesses or assumptions taken from 

water quality research studies in the absence of actual water 

quality data. Using guesses or assumptions rather than 

actual data weakens the model's predictive accuracy. We believe 

that assumptions should be used sparingly for high-cost 

projects and only when they are clearly identified so that 

policymakers may understand and evaluate the risks of 

substituting assumptions for measured values. 

Stream surveys reduce the modeler's need for estimates 

or assumptions. Measurements or calculations may be made 

for such facts as (1) daily variations in DO, (2) BOD rate 

curves showing DO consumption over time, (3) trace minerals, 

(4) toxics, (5) ammonia, (6) streamflows and velocities, 

(7) water temperatures, (8) point and nonpoint sourcesl 

and (9) consumption and production of oxygen by sludge 

deposits and plants. 

We reviewed several modeling studies and observed that 

assumptions were used extensively. Modelers defended their 

use of assumptions by saying they lacked the resources for 

comprehensive studies necessary to develop actual data. The 

number of possible assumptions or combinations of assumptions 

is tremendous. For example: 

--Reaeration rates were obtained from textbooks 

rather than actual instream data. 

--Carbonaceous and nitrogenous BOD rates were 

assumed to be constant for the entire stream rather 

than measured throughout the stream's length. 

--Ice cover, where applicable, was not considered, 

although it affects the reaeration rate, 

--Low flows were assumed to occur only during summer, 

although winter flows may have been even lower. 

--Oxygen demand from sediment deposits was ignored 

or assumed to be constant throughout the stream. 

30 
--Long-term BOD was not measured. Instead, it was 

derived by applying an arbitrary multiplier to 

the 5-day BOD. 

Iowa's modelers used many assumptions in lieu of 

actual data from comprehensive stream surveys. An Iowa 

representative explained that these assumptions had to 

be used because comprehensive surveys were not conducted. 

Accurate BOD values are important because they are 

used for predicting consumption of DO. Models require 

information on long-term (ultimate) BOD. However, such 

measurements are time consuming and require large incubators 

in the laboratory; as a result, they are usually predicted 

from the 5-day BOD. The relationship between long-term 

and 5-day BOD varies from one waste to another and one stream 

to another. In Wisconsin, it was shown in one case 

that the ratio of long-term to 5-day BOD varied from 1.2 to 

6.3. It was also shown that there is no fixed time interval 

for reliably defining long-term BOD. Yet, many modelers 

assume that long-term BOD is always equal to 1.5 times 

the 5-day BOD. For example, the DO model for Rock Creek 

near Sulphur Springs, Texas, explicitly sets the ratio of 

long-term to 5-day BOD at 1.5. The accompanying report, 

however, shows that no one even attempted to measure the 

relationship between long- and short-term BOD. We found 

similar examples at Sac City, Iowa, and Meriden, Connecticut. 

Using assumed values or guesses reduces the model's 

accuracy for predicting the effect of various treatment 

levels on water quality. Consequently, a solid basis 

for the model's recommending costly pollution control 

measures is reduced as more and more assumed values or 

guesses are introduced into the modeling process. 

EPA agrees that models making extensive use of 

estimates and assumed values should not be the sole 

b'asis for recommending costly pollution control measures. 

However, EPA maintains that not every wasteload allocation 

has to be developed through a model that is calibrated and 

verified on field data. EPA believes that in an overwhelming majority of cases, simplified models based on limited 

hydrologic and water quality data can yield sufficiently 

reliable results on required levels of treatment. 

31 
Comprehensive stream surveys are not 

conducted or are taken at the 

wrong time 

Comprehensive stream surveys are generally designed to 

measure all water quality characteristics which significantly 

influence water quality under stressful conditions. Modelers 

often do not use comprehensive stream surveys, and when 

they do, they often do not take measurements when water 

quality conditions are at their worst. When modelers do 

not have essential information on water quality, or obtain 

information when conditions are not at their worst, model 

reliability may be reduced. Water quality modelers we 

spoke with said they had to use assumptions and estimates 

because limited funds reduced the number and quality of 

stream surveys. 

EPA believes that regulatory agencies do schedule 

comprehensive surveys during seasons when low flows generally 

occur; however, it is likely in most cases that sampling 

is done at flows higher than the 7-day, lo-year low flow. 

EPA believes that sampling at flows somewhat higher than 

the 7-day, lo-year low flow in no way detracts from the 

reliability of the data, as long as the sampling period 

is preceded by a period of no rainfall so that instream 

flows are steady. EPA officials also pointed out that 

it is impossible to predict exactly when the 7-&y, lo-year 

low flow will occur and therefore it is impractical to 

attempt sampling only at the 7-day, lo-year low flow. 

We observed a number of situations where stream surveys 

may not have been comprehensive enough to identify water 

quality conditions for all portions of the stream during the 

most critical periods. For example: 

--Raw sewage discharges at Rochester, New Hampshire, 

made it difficult to project future water quality 

and justify treatment beyond secondary. Raw sewage 

masks what water quality would have been under 

secondary treatment. EPA disagrees that this factor 

precludes accurate determination of future water 

quality conditions with secondary treatment. 

--Stream flows substantially above the low flows 

distort stream velocities and DO conditions 

expected during droughts. Stream surveys for Meriden, 

Connecticut, were taken when the river flow was 

32 
over 70 cubic feet per second, or 3-l/2 times the low 

flow of 20 cubic feet per second. EPA believes that 

sampling at this time did not induce an error or 

inaccuracy of a magnitude that would invalidate 

the modeling results. 

--Salmon spawning is proposed as a beneficial use 

for the Rochester, New Hampshire, receiving stream. 

However, stream surveys were not conducted during 

the fall and spring spawning seasons when the river 

is at a higher flow. 

--Many surveys are conducted only during regular working 

hours even though nighttime DO fluctuations may 

be significant. As a result, the DO readings used 

for modeling may not be representative of nighttime 

conditions. 

The Iowa Department of Environment Quality is currently 

consideriny requiring stream surveys for all treatment plants 

beyond secondary. An April 24, 1979, memorandum to the 

Iowa Water Quality Commission proposed: 

"The justification for any advanced treatment levels 

for each facility would be supplemented by extensive 

stream surveys at low stream flow conditions and the 

detailed evaluation of stream aquatic resources." 

We believe that comprehensive stream surveys should be 

made for summer and winter droughts and during high flows 

if WQS may be violated then; the surveys should include 

nighttime DO measurements and time-of-travel measurements in 

the stream. However, information supplied by an EPA task 

force member for our 11 sample projects indicates such 

measurements are not made consistently. For example, of 

the 11 projects: 

--Only three had stream surveys for both summer and 

winter low-flow conditions; the other eight were 

only for summer conditions. No models considered 

high-flow conditions even though in four instances 

WQS were violated during high flows. 

--Seven models did not have DO measurements between 

midnight and sunrise, which we believe is essential 

for accurate DO accounting. 
--Five models were not based on actual, measured time 

of travel or stream velocity. 

A task force representative said that lack of actual data 

forced the use of assumptions and estimates. We believe 

the use of assumptions and estimates increases the chance 

of error; either the treatment plant will be overly stringent 

or WQS will not be met. (See app. I for details on specific 

projects.) 

We discussed the issue of intensive stream surveys with 

EPA officials. One official agreed that use of assumptions 

and estimates in models reduces their reliability. This 

official said EPA is considering requiring intensive stream 

surveys as justification for treatment beyond secondary. 

Some EPA officials informed us that our concept of stream 

surveys is idealistic and unnecessary. They contend 

that the surveys and models may cost more than an AWT project 

for a small community. EPA further maintains that regulatory 

agencies generally identify the critical period in a stream 

on the basis of monitoring and hydrologic information. EPA 

sees no need to require intensive surveys during winter and 

summer low flows, claiming that critical conditions usually 

occur in late summer or early fall and the ice-cover situations are more the exception than the rule. EPA also 

believes that intensive surveys are not necessary in all 

instances. It claims that many generalizations can be drawn 

from existing water quality analyses and that field surveys 

should only be undertaken to resolve uncertainties remaining 

after sensitivity analyses have been performed. According 

to EPA officials, a preliminary model can quite often be 

developed on the basis of limited field data. 

Treatment plant discharges 

are sometimes overstated 

Overstating the amounts of wastewater and pollutants 

discharged from sewage treatment plants during droughts can 

cause overly complex treatment plants to be built. We noted 

an example in Iowa in which the amount of wastewater discharged from a treatment plant into a stream during drought 

conditions was assumed to be an average of the 30 wettest 

days (or largest flows) of the year. Although we did not 

find this type of assumption in other models, we believe 

it illustrates the problems that can arise from poor model 

development. 
The Iowa Department of Environmental Quality developed 

effluent limits for about 300 treatment plants, of which 120 

were expected to require treatment beyond secondary. We chose 

one of the larger treatment plants, Cedar Rapids, to determine 

if it is reasonable to expect stormwater flows to occur while 

the Cedar River (the receiving stream) is in extreme drought. 

Further, we wanted to know if stormwater flows contribute 

the same amount of pollutants as normal sewage effluent. 

We observed that many of the Cedar River's low flows 

occur during the winter, December through February, when the 

ground is frozen. The superintendent of Cedar Rapid's 

Department of Pollution Control informed us that no significant stormwater enters the sewer system during the winter 

since the ground is frozen and the precipitation stays on 

the ground as snow. The superintendent did say that it is 

possible for a 2-inch rain to cause some stormwater flows 

during the summer , perhaps 25 percent more flow, without the 

river rising. However, he said it would be very unlikely that 

stormwater flows could be sufficient to double the average 

flow, as the Iowa model assumes, without the river rising. 

He said he has never observed rain of 2 inches or more when 

the river is flowing near its critical low-flow level. 

In any event the stormwater does not contribute 

significant amounts of ammonia, the most critical pollutant 

discharged into the stream. 

We evaluated low-flow and rainfall data at Cedar Rapids 

for the water years &/ 1911-77. The flow data showed that 

only 26 months, or 3.2 percent of the total, had 7-day low 

flows under 400 cubic feet per second. The State used a 

critical low flow of 346 cubic feet per second for its model. 

We found that of these 26 low-flow months, only 6 had total 

rainfall over 2 inches and in only l--September 1934--did 

the rainfall exceed 2 inches for any two-day period. Consequently, it is highly unlikely that significant stormwater 

will enter the sewers during low flows, much less during a 

critical low-flow period. 

We asked an Iowa engineer to recompute the Cedar Rapids 

effluent limit for ammonia assuming average dry weather flows. 

He determined that the winter ammonia limits would be increased from 7 mg/l to 15 mg/l. The Cedar Rapids superintendent said the consulting engineer estimated $1,600,000 in 

construction costs and $175,000 in annual operating costs 

could have been saved if the less restrictive winter effluent 

limit had been used. 

J/Water years start Oct. first and end Sept. 30. 

35 
EPA representatives said the high and low stormwater 

flows should be evaluated separately. They said future Iowa 

projects requiring treatment beyond secondary should be 

evaluated on this basis since the current Iowa practice can 

permit unnecessarily sophisticated treatment plants to be 

built. 

Streamflow data is 

estimated with substantial 

margins of error 

Most models we reviewed attempt to predict water quality 

at critical low-flow conditions. When actual flow readings 

are not available, or are available for too short a period, 

low flows must be estimated. Such estimates can result in 

large errors. 

Estimated flows are based on available data, usually 

from USGS records. The longer the record, the more accurate 

the estimate, provided there are not complications such as new 

dams. A USGS representative in Iowa said continuous-record 

stations with flow data for 30 years or more produce the 

most reliable estimates, generally within 10 to 20 percent 

of the true value. Partial-record stations with data for 

a shorter period, such as 10 years, may have an error rate 

of 20 percent or more. Estimates must also be prepared, 

however, for streams for which no flow data is available. 

In these cases the measured flow from a similar nearby 

stream is generally used and adjusted based on the relationship of a drainage area to stream flow. These estimates are 

subject to even greater error than partial-record stations. 

We noted five EPA construction grant projects where 

modelers used drainage area to stream flow relationships 

rather than actual flow data: Walworth County, Wisconsin: 

Brockton and Leominster, Massachusetts; Valparaiso, Indiana; 

and Rochester, New Hampshire. 

Many models are not 

properly verified 

Many of the models we reviewed had not been formally 

verified to check their accuracy. Model verification is a 

way of checking whether the model's predictions are right: 

the predictions are compared with actual stream data taken 

after the model was calibrated. If the predictions agree 

with the actual data from the stream, the model has been 

36 
verified; if the predictions do not agree, the model can 

not be trusted because its predictions could not be 

verified. Also, many models did not provide general 

information for decisionmakers on the expected reliability 

of the model results. When poorly constructed models are 

not identified as such, model users can make poor decisions 

about treatment plant design. Thus, WQS may not be met after 

a new, sophisticated treatment plant is built even though 

the model predicted that stream standards would be met. 

We have previously criticized modelers, as have 

experienced analysts, for failing to properly specify model 

reliability. The following comments demonstrate the 

historical concern over the need for verification. 

--"The current trend to attempt application of 

models without verification is shocking. It is 

no wonder that such models are increasingly 

distrusted. In other cases verification and 

calibration [IJ] are based on the same set of data, 

usually poor data at that. In some instances 

where reasonably good calibration and independent 

verification have been made, seldom are limits 

specified within which application of the model 

is feasible. There is also a misconception that 

once a good applied model has been calibrated 

and verified, it can be used indefinitely, even 

though radical changes in river conditions have 

taken place over the years."z/ 

L/Calibration is the procedure in which the model parameters 

are adjusted such that the model output matches the 

observed water quality characteristics of interest. 

g/Presentation by a water quality expert to the National 

Workshop on Verification of Water Quality Models, 

West Point, New York, Mar. 6-9, 1979. 

37 
--"There is no reason to believe that a model is 

capable of approximating reality so well that its 

result can be accepted without reservation. This 

is the case even for those aspects of reality 

pertinent to the purpose the model was designed 

to serve." L/ 

Verification studies which use independent stream 

surveys provide a rough measure of model accuracy. A task 

force member gave us information indicating that independent model verification of stream surveys was not performed 

for 5 of 11 projects in our sample. Virtually all of the 

model documentation we reviewed failed to comment on 

the model's predictive accuracy. We found this to be 

true regardless of whether a formal verification study 

had been made on the model. 

In October 1979 the National Council of the Paper 

Industry for Air and Stream Improvement, Inc., gave us 

a draft copy of its report reviewing use of mathematical 

models for evaluating water quality. This industry 

group sent out a questionnaire to all of the areawide 

planning agencies that engage in water quality modeling. 

Approximately 64 percent, or 118, of 185 agencies responded. 

In reviewing the responses to the survey, we noted 

that many models were not calibrated or verified. An 

assessment of the calibration-verification process was 

possible in 49 of the 118 responses to the survey. Nineteen reported that models were both calibrated and verified: 

22 reported an attempt at calibration only; and the remaining 10 neither calibrated nor verified models. These limitations were generally recognized by the areawide planning 

managers, who cited the expenses involved with data collection as the justification for not verifying models. 

EPA representatives responsible for model review 

said modelers generally do not even provide comparisons of 

predicted and actual DO readings, on which verification 

studies are based. They explained that formal verification 

studies are not conducted usually because of lack of 

intensive stream survey information and lack of skill to 

make such studies. We noted that ti'le verification studies 

apply only to current conditions. The impact that changes in 

L/Exposure draft of "Guidelines for Model Evaluation," 

U.S. General Accounting Office, PAD-79-17, Jan. 1979. 

38 
future pollutant loads have on water quality cannot be 

assessed until the changes actually happen. 

EPA believes that for some types of DO ,modeling, 

calibration and verification never resolve all uncertainties. 

According to EPA officials, future BOD decay rates with higher 

levels of treatment cannot be measured through calibration 

and verification; the water quality analyst still has to 

estimate future rates, although many empirical formulations 

are available for predicting rates. The hydrologic characteristics of a stream can be accurately measured through 

field studies; for example, measuring times of travel 

at different flow conditions. However, ultimately some 

of the key modeling terms, such as rate constants, have 

to be estimated. Therefore, EPA believes that the physical 

characteristics of a stream should be taken from site-specific ' 

field data but chemical calibration and verification 

are not always necessary. 

SOME DECISIONMAKERS ARE 

BEGINNING TO QUESTION 

MODELING RESULTS 

Some decisonmakers are beginning to recognize that 

modeling results are not always reliable. Thus, some 

decisions to construct sewage treatment beyond secondary 

may be based only partially on the modeling results. 

If decisionmakers know that the justification for treatment 

beyond secondary is questionable, they can avoid constructing 

overly sophisticated facilities. For example, increments 

of more stringent treatment might be phased in over a 

period of time if stream surveys demonstrate that lower 

treatment levels are inadequate; uniform effluent limits 

can be established for various types of water bodies: 

or treatment facilities can be designed to produce a "reasonable cost" effluent, no matter what the modeling indicates 

is required. EPA is currently requiring phased construction 

for the larger facilities with treatment beyond secondary 

when modeling does not justify more sophisticated treatment. 

According to EPA, a disadvantage of a phased approach 

for small communities is that they have to go through 

the construction grants process twice. Communities are 

reluctant to do this because of the administrative complexity 

of the program and difficulties in obtaining public support 

for another large bond issue. EPA also believes that in 

a great majority of cases involving proposed AWT, the 

need for treatment beyond secondary can be demonstrated. 
Some advanced treatment 

facilities are built in phases 

and only after stream surveys 

show that further water quality 

improvements are needed 

Treatment facilities beyond secondary may be phased 

in after new stream surveys demonstrate the need for 

improved water quality. Thus, treatment beyond secondary 

is gradually increased until water quality standards are 

reached. The Oklahoma Department of Health, for example, has 

recognized that modeling imprecision makes it difficult to 

establish effluent limits without first partially cleaning up 

the water and then remodeling with the new stream data. The 

department's position statement of May 3, 1979, said that 

construction of facilities for treatment beyond secondary 

should be phased in to allow time for comparing modeling 

results with actual instream data. The position statement 

concluded: 

"When it has been clearly demonstrated through 

verification of models and instream studies that 

treatment beyond secondary is necessary, such 

treatment will be required." 

Blanket effluent limits are 

sometimes used in lieu of 

modeling for certain types 

of water bodies 

Some States use blanket effluent limits that require 

no analysis but instead are based on the type of water body 

into which the plant discharges. This method eliminates the 

need for modeling. Wisconsin, for example, requires all discharges into marshes to have an effluent limit of 20 mg/l for 

5-day BOD and total suspended solids. A Wisconsin Department 

of Natural Resources official said this requirement was 

instituted because the impact of sewage discharges on 

marshlands cannot be accurately modeled. 

Effluent limits more stringent 

than secondary are limited 

based on cost or operational 

constraints 

Several States limited the level of stringent treatment 

no matter what modeling demonstrates is needed. Representatives from several States said high construction and operation 

costs plus operational problems necessitated limitations 

for the most stringent treatment facilities. Iowa and 

Wisconsin, for example, generally require no more stringent 

40 
effluent limits than 10 mg/l for 5-day BOD and total 

suspended solids, and Illinois generally requires effluent 

limits no more stringent than 10 mg/l for 5-day BOD and 

12 mg/l for total suspended solids. 
CHAPTER 4 

THE HIGH COSTS OF GOING BEYOND SECONDARY 

TREATMENT ARE NOT ADEQUATELY CONSIDERED 

IN SETTING STANDARDS 

AWT IS EXPENSIVE 

The costs of constructing advanced waste treatment 

facilities are high. Related costs, such as those to reduce 

nonpoint pollution and combined sewer overflows, are also 

high. Other related costs involve plant operation and 

maintenance (O&M), other environmental improvements needed 

before AWT can improve water uses, and negative environmental 

impacts associated with AWT. Generally, the act does not 

authorize EPA to require States to compare costs in setting 

or revising standards. Even when costs may be considered, 

EPA limits the extent they can be compared to the significance 

of the violations they are intended to correct. 

Capital costs 

The capital cost of constructing AWT facilities is 

substantial. The 1978 Needs Survey for constructing waste 

treatment facilities identified $10.3 billion as needed for 

treatment beyond secondary to bring the Nation's waters 

up to the goals stated in the Clean Water Act. 

Operation and maintenance costs 

Nearly every wastewater treatment plant is more 

expensive to operate, maintain, and repair over its lifetime 

than to construct. The average O&M costs for AWT per million 

gallons of sewage treated are much greater than for secondary 

treatment. An EPA contractor studying O&M costs for various 

size treatment plants found that the average cost per pound 

of oxygen-consuming material removed was nearly 9 times 

higher for AWT than for conventional secondary treatment 

plants; for suspended solids, the AWT cost was nearly 10 

times more per pound removed. The cost differential is 

not nearly as great for larger plants, especially those 

treating 5 million gallons per day and over. Thus, small 

plants are relatively more costly to operate. 

Water quality experts in several States we visited also 

stressed that facilities providing treatment beyond secondary 

are far more difficult to operate than traditional secondary 

treatment facilities. Operating problems are especially 

42 
prevalent in rural areas where it is difficult to obtain 

highly skilled treatment plant operators. 

Illinois EPA officials said their experience with the 

most sophisticated treatment plants showed that few facilities can produce a very high quality effluent. For example, 

an EPA study entitled "A Critical Evaluation of Current 

Performance of Some Activated Sludge and Lagoon Systems in 

Illinois" summarized the effluent quality of a variety of 

treatment processes over a wide range of operating conditions. One hundred and twenty-five plants that may be considered to have AWT were studied intensively. The study 

concluded that only two of the facilities could consistently 

produce an effluent of 4 mg/l 5-day BOD and 5 mg/l total 

suspended solids. 

Costs of other needed 

environmental improvements 

In some cases large expenditures will be needed for 

other environmental improvements before AWT facilities can 

significantly improve water quality. According to an EPA 

consultant, "One may spend a fortune on [building waste 

treatment plants] only to find that the water is still far 

below standard." Nonpoint source pollution may negate pollutant reductions obtained from point source control and 

prevent desired beneficial water uses even after AWT facilities are operating. But reducing nonpoint source pollution 

usually involves considerable expense. For example, EPA 

estimated that $10 billion would be needed to solve problems 

caused by agricultural runoff. In addition, EPA's 1978 Needs 

Survey estimated that $26 billion would be required to 

solve the nationwide combined sewer overflow problem. 

Although EPA estimates that nonpoint sources account 

for more than half of the pollutants entering the Nation's 

waterways, the effects of nonpoint sources are often 

neglected in determining the need for AWT plants. 

Counterbalancing environmental effects 

Correcting WQS violations may have counterbalancing 

environmental effects which, in our opinion, should be considered as part of the treatment costs. Some AWT is designed 

to reduce nutrients (especially phosphorus and/or nitrogen) 

and thus prevent nuisance algal blooms which make lakes less 

attractive and swimming less enjoyable; these algal blooms 

may also reduce oxygen levels in the water. However, removing 

nutrients is not necessarily beneficial because it may also 

reduce the fish food supply and thus impair the quality of the 

fishery. According to a professor of water quality 

43 
engineering, poor fishing is associated with the total absence 

of pollution. In fact, fertilizer sometimes is used in 

commercial and sport fisheries to add nutrients, to produce 

algae for the fish to eat. Nutrient removal also may reduce 

large aquatic weeds, which may interfere with swimming and 

boating but which seem to make a good environment for fish. 

In addition, clean, sandy beaches ideal for swimming are 

preferred by the snail which is associated with outbreaks 

of "swimmers' itch." 

COSTS HAVE NOT BEEN .ADEQUATELY 

CONSIDERED IN SETTING STANDARDS 

EPA assumes that a State will determine the economic 

feasibility of achieving WQS before setting them, but that 

kind of analysis is seldom done. States tend to classify 

waters as fishable and swimmable in the absence of clear 

information to the contrary, and obtaining EPA approval 

to reclassify downward is very difficult. The law does not 

provide for costs to be adequately considered in the 

standard-setting process. 

The standard-setting process assumes 

costs will be analyzed, but they seldom are 

EPA regulations provides for States to consider economic 

and social factors in determining attainability of standards. 

According to EPA officials, a State is expected to ensure 

the economic reasonableness of attaining the water uses 

it designates in a standard. These officials said that 

when a water body is given a fishable/swimmable designation, 

EPA presumes that the State has determined that these uses 

can be attained economically. 

However, State and EPA regional officials stated that 

States generally do not perform economic studies to determine 

whether the fishable/swimmable standards can be attained 

at a reasonable cost. For example, a large number of small 

streams in Washington are designated as a group for one 

classification due to sheer numbers and lack of data. 

We were told that it would be virtually impossible to classify 

individually the thousands of small streams in the State 

with any accuracy. A similar situation exists in Alaska. 

According to an EPA official, determining the appropriate 

use designation for all the streams in Alaska would require 

a large-scale study lasting many years. Alaska has an estimated 3 million lakes over 10 acres in size, and.the total 

number of Alaskan river-miles is so vast that realistic 

estimates have not yet been produced. 

44 
According to this EPA official, most States classify 

many streams in some general way, expecting to make exceptions to the general classification as they obtain more 

information. Other EPA regional officials sa.id the cost of 

bringing certain bodies of water up to a standard was not 

considered'in setting the standard. 

Overclassification may be common, 

but reclassifying a water body 

downward is no easy matter 

EPA reyional officials stated that in the absence of 

firm data, States tend to overclassify water bodies. For 

example, an EPA regional official said that all freshwater 

streams in Alaska are classified for virtually all uses, yet 

many have been destroyed --perhaps almost irretrievably--by 

small-scale gold mining. He said that eventually Alaska 

will have to request downyrading or prohibit mining. He told 

us that the tendency of States to overclassify was caused by 

the fear that errors in underclassifying water might destroy 

fish and wildlife habitats, perhaps irretrievably. 

Sewage treatment officials in Seattle said that 

small streams in their area had also been overclassified 

because of a general classification. The director of the 

Illinois Environmental Protection Agency told us that his 

agency believes that many of its classifications are inappropriate and represent the idealistic enthusiasm that prevailed 

in the early 1970s when the standards were set. Many Illinois 

streams cannot support a viable fishery or swimming and 

boating activities because of their physical limitations, 

surrounding land use, or both. 

To obtain EPA approval to reclassify a water body 

downward, a State must demonstrate that a standard cannot be 

attained. Downward reclassification is possible only where 

a particular water body is not attaining its designated use 

or is attaining the use but not the water quality level 

supposedly necessary to support that use. For example, the 

water body may actually be used for fishing, but the DO levels 

supposedly necessary to support fishing may regularly fail to 

meet recommended DO criteria. 

EPA will approve downgrading only if a State demonstrates 

that the designated use,. or at least the criteria set for 

that use, are unattainable because of (1) natural background, 

(2) irretrievable person-induced conditions, or (3) existing 

point sources that would have to go to treatment beyond secondary would result in substantial and widespread adverse 

economic and social impact. 

45 
EPA has defined "widespread" as at least as large as a county 

or a standard metropolitan statistical area. 

In March 1979 EPA reported that 36 States had reviewed 

their WQS since 1975, and 9 had downgraded the designated 

uses for one or more streams. EPA has approved few of 

these requests for downgrading. 

An EPA headquarters official reported that the number of 

downgradings has depended on State and EPA regional office 

attitudes toward the program. He stated that EPA regions 

that take a hard line on standards' revisions often force 

States to make extensive justification for any changes. In 

general, EPA discourages downgradings. 

According to another EPA official, it is extremely 

difficult for States to obtain approval to downgrade designated water uses. He told us that EPA requires very detailed 

justification and formal public hearings. An Oregon official 

told us that Oregon has not requested any downward reclassifications of uses because of the expensive, time-consuming 

process involved. 

Our review of several downgrading actions revealed that 

extensive negotiations are usually necessary and can take 

from 4-l/2 months for a single stream to 21 months or more 

if numerous streams are involved. Adequately documenting 

and justifying downgradings can be costly to a State. For 

example, according to an EPA official, a downgrade was 

approved for a creek in Virginia after a consulting firm 

prepared an extensive study of the economic impact on one 

plant. According to this official, the study cost $25,000. 

Another EPA official told us that an economic analysis 

similar to the one done for Virginia would cost more for 

larger plants. 

EPA does not have explicit guidance on the type and 

extent of economic analyses needed to justify a downward 

reclassification. According to an EPA official, EPA regions 

are not consistent in defining "substantial and widespread 

adverse economic and social impact" and in deciding how 

economic analyses should be done. EPA is now developing 

more explicit guidance on the kinds and extent of information 

that States should submit. EPA estimates that it will issue 

a program guidance memorandum around October 1980. 

Generally States have tried to reduce classifications 

for one of two reasons. Either (1) the States consider the 

cost to make a stream fishable/swimmable an excessive burden 

to municipalities, which would have to build and operate 

46 
expensive AWT projects, or (2) the physical condition of the 

waters is such that it prevents or restricts attainment of a 

fishable/swimmable status. For example, the streams may be 

contaminated by acid mine drainages; may have,been channelized, which reduces fish habitat; or may have low or shallow 

flows not suitable for swimming or full-time fish habitat. 

Two of the following downgrading attempts were based on 

costs (Alabama and Ohio) and one was based on physical conditions of the waterways (Nebraska). 

Alabama 

Alabama forwarded proposed downgradings to EPA region 

IV in June 1977. The region approved 7 downgradings but 

disapproved 50 other stream-use classifications. Twenty 

were disapproved because the State had not justified why the 

reduced-use classifications had been made, and 30 were disapproved because EPA believed the higher use could be or was 

already being attained. 

Alabama resubmitted 29 of the stream-use classifications, but 23 were again disapproved by EPA region IV in 

February 1978. EPA disapproved the reclassifications because it believed the State could not adequately justify 

that the streams either could not support fish life or could 

do so only at excessive cost. In February 1979 the State 

provided EPA additional information for these streams: however, EPA had still not completed action on the proposals 

by March 1979, 21 months after negotiations began. 

Piney Creek is an example of the negotiations and 

controversy involved in the Alabama downgradings. In 

September 1977 EPA disapproved changing the use from fish 

and wildlife to agriculture and industrial water supply 

because the need for the downgrade was not demonstrated. 

In January 1978 Alabama showed that the town of Ardmore has 

a very small wastewater treatment plant discharging into Piney 

Creek but would need an AWT plant to maintain fish and wildlife standards in the stream. The stream at times goes dry, 

and the State Department of Conservation and Natural Resources 

does not believe Piney Creek is suitable for a fish and 

wildlife use classification. The State concluded that the 

town of Ardmore would suffer "adverse economic impact" if 

required to build and operate an AWT plant. 

In February 1978 EPA disapproved the downgrading 

proposed for Piney Creek because 
--the State did not demonstrate that the fish and 

wildlife use was unattainable and 

--the increased sewer charge per family would be only 

1.11 percent of the 1977 estimated median family 

income and thus insufficient to demonstrate 

substantial adverse economic impact. 

In November 1978, after public hearings were held on 

the proposed downgradings, Alabama again requested approval 

of the Piney Creek downgrading. The State said that new cost 

data showed sewer charges for the Ardmore AWT plant would 

equal about 1.76 percent of the 1977 median family income 

(about $190 a year) if an AWT plant had to be built. The 

State also said that the creek had very low DO upstream from 

the Ardmore plant, which indicated that the natural stream 

could not meet DO criteria for fish. 

In January 1979 EPA region IV referred the Alabama 

classification problem to EPA headquarters for further 

action. EPA region IV stated that, for Piney Creek, the 

1.76-percent median family income figure for sewer costs was 

still insufficient to demonstrate adverse economic impact. 

In addition, the information on natural stream conditions 

was questionable since it was not clear whether it was 

based on more than a single measurement. Thus, the region 

stated that Piney Creek should remain designated for fish and 

wildlife use. 

Ohio 

Ohio submitted revised WQS to EPA region V in February 

1978. Ohio had proposed a "limited warmwater habitat" use 

classification because of the 

--severe hardship faced by a municipality required to 

upgrade its sewage facility at its own expense when 

scheduled Federal funding would not be available soon 

enough, 

--existence of low streamflows, and 

--limitation of wastewater treatment technology or the 

presence of irreversible conditions caused by acid mine 

drainage. 

The State also proposed a "seasonal warmwater habitat" 

use classification, which would require higher water quality 

only at fish reproduction and habitation seasons in low-flow 

streams. The State believed that a higher use classification 

48 
at all times would require AWT and cause economic 

hardship. 

However, EPA believed that two of the use classifications, which applied to about 40 streams, constituted downgradings and had to be justified by documentation. EPA 

believed the lack of available grant funds did not justify 

downgradings because the problem could be alleviated by caseby-case time extentions. After extensive negotiation between 

the State and EPA, the question on uses was still not resolved 

as of March 1979. 

Nebraska 

Nebraska, which is in EPA's region VII, proposed to 

reduce the use classification for some of its waters from 

fishable/swimmable to either fishable with partial body contact or to eliminate all uses. The State believed that some 

waters were physically not acceptable for fishing and swimming 

because they had only intermittent flows, were too shallow, 

or were too swift. 

When EPA initially disapproved the proposals, Nebraska 

reestablished 12 streams as fishable/swimmable and downgraded 

7 others to fishable with partial body contact, such as for 

boating and wading but not swimming. EPA approved these 7 

downgradings but disapproved 11 others the State had proposed 

and issued an official ruling designating the higher use 

classifications. EPA considered the waters to be suitable 

for full body contact and therefore believed they should 

be protected. 

Variances require similar justification 

Rather than reclassifying a stream segment, some States 

grant variances to individual dischargers for a limited time 

for a particular water quality constituent or constituents 

because of "unattainability." The downward reclassification 

has the effect of lowering many criteria, while the variance 

applies to only one or a limited number of criteria. When 

one or several criteria for a use designation cannot be met, 

the use-- although possibly somewhat impaired--is generally 

not lost. Issuing variances for criteria which cannot 

reasonably be attained continues to protect the designated 

use to some degree. Such variances are acceptable to 

EPA only if the State can provide the same type of justification required for downward reclassifications. 
Downward reclassifications * 

may become even more difficult 

On July 10, 1978, EPA announced it was considering a 

proposal to make the socioeconomic justification of downward 

reclassification even more stringent. The proposal would 

require the State to show that 

--all nonpoint sources have been controlled to the 

maximum extent feasible and 

--the economic and social costs of the additional point 

source and nonpoint source controls necessary to 

attain the currently designated use would not be 

reasonable compared to the resulting benefit. 

EPA is also considering proposing that the States designate 

all water as fishable/swimmable (and thus generally subject 

to EPA-recommended criteria) except where the State can--on 

a case-by-case basis-- justify a downward reclassification. 

EPA estimates that it will prepare revisions to its existing 

WQS regulation in September 1980. 

EPA allows only limited cost 

considerations in the use 

designation process 

EPA does not permit downward reclassification of a 

fishable/swimmable standard because of cost--even if no 

reasonable relationship exists between costs and benefits-- 

unless, substantial and widespread adverse economic and 

social conditions will result. Under the present proposal, 

even if these adverse conditions exist, the downward reclassification will not be permitted unless the State can 

prove that nonpoint sources have already been controlled to 

the maximum extent feasible and that no reasonable relationship between costs and benefits exists. Thus, even if a 

State shows that the costs of attaining WQS will seriously 

damage local economies, EPA apparently will not permit 

the State to lower the use designation as long as--in EPA's 

judgment --the benefits associated with attaining the standards have some reasonable relationship to the costs. 

In addition, by never permitting a downward reclassification from a use currently attained--except when a use is 

being attained but the EPA-recommended water quality criteria 

for that use are not being attained --EPA ignores the possibility that local economic pressures or changes in industrial 

or agricultural patterns may justify reclassifying a stream 

50 
use downward. For example, as an area becomes more industrialized, the industrial discharges may reduce water quality; 

the benefits associated with the increased industrialization, 

however, may justify accepting this reduction in quality. 

EPA also recognizes the probability of severe adverse 

economic impact when project service costs (debt retirement 

charges and operational charges) represent more than a certain percentage of median household income. This percentage 

increases as median household income increases, ranging from 

l-1/2 percent for under $6,000 to 2-l/2 percent for over 

$10,000. These guidelines are not rigid but are merely rules 

of thumb. An EPA official told us that projects exceeding 

the guideline percentages may be funded. The costs permitted 

by the guidelines are substantially higher than current costs 

actually paid for.sewer services. Using a Bureau of Labor 

Statistics study, EPA estimated the cost of sewer services 

is approximately 0.2 percent of median family income. The 

EPA guidelines thus allow project costs to cause sewer 

charges to rise to 7.5 to 12.5 times the present level of 

charges. 

EPA recognizes, somewhat, the costs of preventing 

violations of water quality criteria in several other ways. 

For example, EPA allows water quality criteria violations 

within mixing zones (limited areas around discharge points). 

Concentrations of pollutants in these zones may approach 

levels which kill half a test group of fish within 96 hours. 

According to EPA's "Quality Criteria for Water," the permissible size of a mixing zone depends on the "acceptable amount 

of damage" and the "relative social and ecological values 

of the aquatic life that may inhabit a particular waterway 

area." In addition, EPA allows violations of WQS during 

extremely low-flow conditions, apparently recognizing that 

resulting damage is not worth the cost of prevention. 

Finally, EPA's recommended criteria for such aspects 

of water quality as DO and pH may be considered a 

socioeconomic decision, not a biological one. In fact, 

the Director of EPA's Environmental Research Laboratory 

in Duluth wrote in March 1979: 

"In regard to the DO question, there is no question 

that a minimum of 5 and an average of 6 is better 

than an average of 5 and a minimum of 4. The 

question is the significance of that difference 

and whether it is worth the cost. Certainly no 

one can argue that the fish fare as well at 

minimums of 4. The real issue boils down to how 

much benefit we would gain * * * ." 

51 
EPA has effectively minimized the 

States' ability to tailor WQS 

to local conditions 

EPA admits that its recommended criteria do not take 

into account the variability of waters from State to State. 

Even so, EPA presumes the criteria apply to all streams, subject to change only upon States' presentation of what EPA 

describes as "adequate technical justification" and what the 

Association of State and Interstate Water Pollution Control 

Administrators describes as "overwhelming contradictory information." According to a May 1979 report of the Association 

of State and Interstate Water Pollution Control Administrators, EPA stiffly opposes any relaxation of certain water 

quality characteristics (DO, ammonia, phosphorus, iron, or 

lead) to levels that can be reasonably achieved. The report 

declared that although EPA rarely promulgates WQS, it has 

considerable control over State-adopted WQS through its 

approval/disapproval authority. 

52 
CHAPTER 5 

QUESTIONABLE AWT PROJECTS ARE BEING FUNDED 

Many AWT projects have been judged to have been 

construct,ed without adequate justification. As a result, 

the Appropriations Conference Committee, in appropriating 

EPA's fiscal year 1979 construction funds, required 

EPA to ensure that large AWT projects would definitely 

have signficant environmental and public health improvements. This requirement seems to conflict with the Clean 

Water Act, as discussed in this chapter. Although EPA 

believes it is following the Appropriations Conference 

Committee's mandate for definite and significant improvements, 

the environmental and public health benefits expected from 

recently approved AWT projects continue to be questionable. 

EPA has weakened the Appropriations Conference Committee 

restriction on large AWT projects considerably by 

--exempting various types of advanced treatment from the 

review process, 

--not requiring public health improvements in most cases, 

and 

--not emphasizing enough the requirement that the impact 

of AWT on water quality must be highly certain. 

The weakening of the Appropriations Conference Committee 

restriction may be due to an apparent conflict between it and 

the Clean Water Act. Whereas the act requires whatever level 

of treatment is needed to attain WQS regardless of the 

significance of improvements in water quality, the restriction 

limits Federal funding to those treatment projects that will 

definitely and significantly improve water quality. 

INADEQUATE JUSTIFICATION IN PRIOR 

YEARS FOR AWT 

In recent years we and others have been critical of the 

justification for wastewater treatment beyond secondary. 

--A 1976 GAO report "Better Data Collection and 

Planning is Needed to Justify Advanced Waste 

Treatment Construction" (CED-77-12, Dec. 12, 1976) 

questioned the environmental impact of various AWT 

facilities. The report pointed out that some AWT 

facilities were developed on the basis of special 

53 
studies but without adequate knowledge of sitespecific causes of the water quality problems 

and without knowing how the AWT facility would 

improve water quality. 

--A report was prepared for EPA by a consultant to 

evaluate a number of AWT projects, carefully chosen 

from lists of outstanding candidates prepared by 

EPA and State agencies, to try to find the country's 

best projects. The report concluded that all the 

projects were based on bungled justifications and that 

"it is probably safe to assume that nearly every 

other example of AWT planning in the U.S. is at least 

as poor as these six." 

--EPA's 1978 review of 330 AWT projects that had 

been proposed to meet very stringent effluent limitations indicated that about half the projects 

lacked adequate site-specific receiving water data. 

EPA officials further indicated that, in reviewing 

grant applications for AWT in the past, little 

consideration had been given to the impact of AWT 

on water quality as long as AWT was needed to meet 

WQS. 

--A March 1979 report by the Surveys and Investigations 

Staff of the House Appropriations Committee discussed 

AWT facilities that had been built in the late 

1960s and early 1970s. The report found shortcomings 

in virtually every facility visited. 

--In September 1978 EPA regions were asked to submit 

to EPA headquarters two of the best examples of water 

quality planning that resulted in treatment beyond 

secondary. In a December 18, 1978, memorandum for 

the record, an EPA environmental specialist reported 

that the good examples, on the whole, were discouraging. Of the 18 projects submitted, he identified 12 as suspect: 

--Four projects were on intermittent or very 

small streams. 

--Three projects were justified by a State-imposed 

blanket effluent limit or a dilution policy. 

--Three projects were based on limited data. 

--Two projects involving ammonia removal were 

based on current and projected instream 

ammonia levels in excess of EPA criteria, 

54 
even though the streams supported an excellent 

fish population with no apparent ammonia 

toxicity problems. 

The memorandum stated that, in many cases, State WQS and 

effluent policies are forcing AWT on water quality managers 

without adequate technical analysis. 

THE SIGNIFICANCE AND/OR CERTAINTY OF 

ENVIRONMENTAL BENEFITS EXPECTED FROM 

LARGE-SCALE AWT PROJECTS 

CONTINUE TO BE QUESTIONABLE 

In approving the fiscal year 1979 appropriation for 

EPA's Construction Grants Program, the Appropriations 

Conference Committee stipulated that construction grant 

funds may be used for treatment beyond secondary only if 

(1) the incremental cost of AWT is $1 million or less 

or (2) the Administrator personally determines that 

AWT is required and will definitely result in significant 

water quality and public health improvements. 

EPA agreed that rigorous case-by-case analyses should 

be encouraged, and it implemented the Appropriations Conference Committee restriction through a program requirements 

memorandum in March 1979. Earlier guidance had been 

provided in a June 8, 1978, memorandum. The program requirements memorandum requires most projects with an AWT increment over $1 million to be reviewed by EPA headquarters 

and authorized by the Administrator before approval. 

According to an EPA official, as of December 31, 1979, 

EPA headquarters has had 74 projects submitted for review; 

final decisions have been made on 50 projects costing 

$1,878 million in total; and capital cost savings from these 

decisions have totaled $90.2 million. Decisions on more projects are pending, with a potential additional capital cost 

savings of over $9 million. EPA officials claimed that the 

inflationary loss of purchasing power due to delays of the 

original projects caused by these reviews is estimated at 

$93 million for capital costs. According to EPA officials, 

this loss cannot be directly compared to the cost savings 

achieved by these reviews since the costs are losses in 

purchasing power and the savings are real resource savings. 

Despite EPA's review and authorization, four of.five 

projects we reviewed had questionable aspects--ranging from 

high uncertainty to minimal environmental impact and low 

social siynificance-- concerning their appropriateness. 

These projects are discussed below. 
Rochester, Minnesota 

EPA approved a project for Rochester, Minnesota (with a 

$10 million AWT increment), designed to limit (1) ammonia and 

BOD to protect aquatic life in a river and (2) phosphorus to 

reduce algal growth in a nearby lake. State fisheries officials, however, told us that proposed flood control projects 

are expected to devastate the fishery downstream from 

the treatment plant. One fisheries official was uncertain 

whether enough fisheries resources would remain to warrant 

AWT. 

In addition, it appears that the flood control projects 

would change the low-flow ammonia and DO levels. The levels 

would increase or-- if flow augmentation were practiced--would 

make the degree of AWT unnecessarily stringent. 

Experts are divided on the value of removing phosphorus. 

Some say it will reduce algae noticeably and improve uses 

of the lake, whereas others say algae will not be reduced, 

or not enough to affect water uses. One expert suggested 

that undesirable forms of algae may become more dominant. 

Several experts thought that it might not be possible 

to reduce nonpoint sources of phosphorus enough to change 

the algae discernibly. 

St. Petersburg, Florida 

EPA headquarters authorized regional approval of a 

project at St. Petersburg, Florida (with an $8.03 million AWT 

increment), exempting it from review because it featured 

land application of the effluent. The project will use 

effluent to spray-irrigate various green areas, thereby 

reducing the use of drinking water for the same purpose. 

As a public health measure, the AWT effluent will be made 

clearer than drinking water and chlorinated to remove 

viruses, before it is sprayed. 

City officials said they anticipated no water use 

improvements as a result of the project because there are no 

uses reasonably desired for the receiving water (Boca Ciega 

Bay) that are not now being attained. The Director of the 

Center for Mathematical Modeling at the University of South 

Florida told us that most of the bay's waters are of acceptable quality with problem areas (low DO, algae, odors, and 

fishkills) in bayous and inlets which have limited flushing. 

He said that even if sewage is removed totally, these areas 

will still have severe nonpoint source pollution problems 

but the extent and severity of the problems will be lessened. 

56 
The project's principal benefit appears to be 

that it will reduce peak demand for drinking water in 

st. Petersburg sufficiently to postpone--perhaps indefinitelY --expensive expansion of the municipal water, supply system. 

Expansion of a municipal water supply system for a city like 

St. Petersburg would not be eligible for Federal funding. 

Walworth County, Wisconsin 

A project in Walworth County, Wisconsin (with a $4 

million AWT increment), will remove three secondary discharges 

into or above a shallow, eutrophic lJ natural lake and one 

secondary discharge into a creek downstream of the lake. 

Instead of discharging into the lake, the project will 

discharge AWT effluent into the creek. 

EPA's internal review concluded that the project's 

impact on lake eutrophication could not be predicted. 

Although EP&'s summary claims that existing water quality 

and uses of the creek would be somewhat enhanced by the 

project, the State's modeling study shows that when the 

plant reaches full capacity sometime in the future, DO 

levels of 3 mg/l will often occur in the creek. EPA recommends a minimum of 5 mg/l for protection of aquatic life--a 

level which would not be met even with zero discharge 

at the planned facility. In addition, in spite of the 

advanced treatment, ammonia levels in the 6 miles immediately 

downstream of the discharge are projected to be four times 

greater than the criterion recommended by EPA to protect 

aquatic life. The effects of the AWT increment were 

not shown separately from other aspects of the project. 

Finally, although one of the project's purposes is to 

restore the creek as an excellent smallmouth bass stream, 

the creek has become shallow and wide; it supports mostly 

carp and trash fish and lacks habitat suitable for gamefish. 

These physical changes severely limit the extent to which 

the project can improve the use of the creek. 

Leominster, Massachusetts 

A project at Leominster, Massachusetts (with a $1.26 

million AWT increment), is expected by EPA and State officials 

to upgrade the fisheries and recreation potential of the 

generally scenic and undeveloped area of the Nashua River. 

However, the social impacts of the improvements appear 

negligible because other nearby water bodies provide 

similar recreational resources. 

A/Rich in dissolved nutrients, such as phosphates. 

57 
According to State environmental and fisheries 

officials, the Nashua River provides the area's only potential for good warm-water stream fishing. Other lakes and 

ponds, however, also provide good warm-water fishing; The 

fisheries officials said the Wachusett Reservoir near 

Leominster also provides excellent bank fishing for bass 

and lake trout. They told us one impounded area of the 

river was much like a lake because it was wide and sluggish. 

According to State environmental officials, tributaries to 

the river provide cold-water fishing. 

The Director of Public Works for the City of Leominster 

told us that the local area has many alternative water bodies 

(for fishing, boating, and swimming) and to spend money 

on the Nashua would be wasteful. He believed that it would 

not be a great loss if the Nashua remains as it is. He said 

that the Squannacook River (a tributary of the Nashua) provides good fishing and that it and other fishing streams 

are not overcrowded now that year-round fishing is permitted. 

MANY INAPPROPRIATE SMALL-SCALE AWT 

PROJECTS ARE STILL BEING APPROVED 

The Appropriations Conference Committee report did not 

restrict expenditures for projects with AWT increments 

under $1 million. However, EPA has required that such projects be reviewed intensively at the regional level to 

ensure they will provide significant water quality and public 

health benefits. In spite of this requirement, regional 

offices are still approving AWT projects that are not likely 

to provide significant benefits. 

As of September 30, 1979, 178 projects with AWT 

incremental costs under $1 million had been reviewed by 

EPA regional offices since the Appropriations Conference 

Committee imposed the restriction on large AWT projects. 

The total incremental AWT cost for these projects is $64.6 

million. We reviewed four of the projects approved by EPA 

regional offices and believe that all were questionable, 

either in whole or part. 

Sac City, Iowa 

Ammonia is to be removed by a project approved for 

Sac City, Iowa (with a $4.00,000 AWT increment), although 

since 1971 no ammonia levels attributable to Sac City's 

effluent have violated present WQS. The requirement for 

ammonia removal was based on a State wasteload allocation 

accepted by EPA region VII. However, new (1979) wasteload 
allocations show little difference in instream ammonia with 

or without ammonia removal at Sac City. According to a State 

game warden, the receiving water already has the best smallmouth bass and walleye fishing in the State. 

New Concord, Ohio 

The $350,000 AWT increment in the project approved 

for New Concord, Ohio, will produce benefits which appear 

to be of marginal ecological and no social significance. 

The receiving water is too small to support much desirable 

fish habitat and is not used for fishing or swimming. According to the design engineer, even changing the sewage discharge 

to distilled water would not change existing water uses. 

A New Concord official told us that fishkills do occur 

when the present secondary plant discharges into a nearly 

dry stream. But the district chief of the State's Fish 

and Wildlife Division said the fishkills were of limited 

ecological significance because they were limited to a short 

distance below the plant and the area was repopulated within 

a short time by fish from a much larger creek downstream. 

He also said there has been no evidence of species change 

associated with the plant's present effluent. 

The project includes filtration to reduce BOD and 

suspended solids from roughly 10 mg/l (without filtration) 

to 7 my/l (with filtration). The design engineer said the 

additional features were silly and involved a large additional 

cost to buy something of no use to anybody. 

Sulphur Springs, Texas 

In a project approved for Sulphur Springs, Texas, a 

sand filter (costing $600,000 in AWT funds) is planned to 

reduce BOD from 20 mg/l to 10 mg/l and suspended solids from 

20 mg/l to 10 mg/l; these changes were justified to keep DO 

in the stream at 2 my/l under low-flow conditions. The 

1974 wasteload evaluation on which the effluent limits were 

based was a primitive effort based on sketchy data. A better 

evaluation was completed in 1979, and although it too had 

deficiencies which cast doubt on its accuracy, it showed 

that the filter would protect only about a l-mile stretch 

of the receiving stream (Rock Creek) as it passes through 

open country to prevent the DO from falling below 2 mg/l. 

The DO level of 2 mg/l represents a margin of safety over 

anaerobic (zero oxygen) conditions; it is designed to 

protect the water from stinking, which might occur at zero 

DO, but 2 mg/l is arbitrary. The plant discharges into 

Rock Creek, which in turn flows into White Oak Creek about 
10 miles further downstream. Both creeks are very small; 

neither has a specific use classification. 

Sandusky, Michigan 

A project approved for Sandusky, Michigan (with a 

$619,000 AWT increment), is designed to meet very stringent 

effluent limitations (for example, summer monthly averages of 

BOD = 4 mg/L ammonia = 0.5 mg/l). The effluent limitations 

were set to achieve WQS for Dwight Drain. The plant discharges into Berry Drain which joins Dwight Drain several 

miles downstream. The State classifies virtually all waters 

for at least a warm-water fishery and has so classified 

Dwight Drain. State fisheries officials, however, said 

the drains had no potential as fisheries. 

According to State environmental officials, the effluent 

limitations were also set to ensure that no nuisance problems 

(odor) occur even at very low flows when the stream is 

entirely composed of sewage effluent. However, State officials were uncertain whether odor problems would result 

if these standards were relaxed. We believe the impact 

of the polishing pond, which will reduce the average summer 

BOD from 10 to 4 mg/l, will be insignificant since the 

odor problems occur infrequently and appear to be related 

to combined sewer overflows. Other aspects of the project 

will eliminate the overflows. 

THE CONGRESSIONAL RESTRICTION 

ON AWT PROJECTS HAS BEEN WEAKENED 

EPA has weakened the congressional restriction by 

--exempting various types of advanced treatment from the 

review process, 

--revising the requirement for significant public health 

benefits, and 

--not emphasizing the requirement for a high level of 

certainty that AWT will significantly improve water 

quality. 

Various types of AWT exempted 

Although EPA agreed that rigorous case-by-case analyses 

should be encouraged, it has exempted various types of AWT 

from review. According to EPA officials, these exemptions 

were made because EPA believed they were consistent with 

priorities set forth in the Clean Water Act or were not 

relevant to the concerns that led the Congress to require AWT 

reviews. 

60 
Projects involving land treatment or other reuse/ 

recycling technology are generally exempted from special 

review for significant water quality and public health 

improvements as long as the cost is not excessive. According to EPA officials, EPA's policy is to encourage projects 

involving land treatment or other technologies promoting 

recycling and reuse of pollutants or reduction of energy 

requirements. AWT cost is not considered excessive as long 

as it does not exceed the cost of a secondary treatment 

facility by more than roughly 25 percent (or by more than 

roughly 50 percent in the case of a very stringent AWT project) and as long as the total average annual cost to a 

domestic user does not exceed a certain percent (1.5 to 

2.5 percent) of the area's median household income. Nationwide, average sewage treatment costs represent 0.2 percent 

of median household income. EPA exempted the $8 million 

AWT project at St. Petersburg, Florida (see p. 56), from the 

AWT review process because it met these requirements and 

because it involved land-application of AWT effluent. 

Projects for achieving effluent levels of BOD and 

suspended solids below the levels EPA requires for secondary 

treatment do not have to be reviewed if the State has defined 

secondary treatment more stringently than EPA and if the 

extra costs would be a small percentage of the costs of the 

treatment facility. For example, Texas has set 20/20 BOD/ 

suspended solids as its definition of secondary treatment, 

whereas EPA's definition is 30/30. According to an EPA project engineer, however, any large plant built today to achieve 

30/30 effluent will have sufficient sophistication to reach 

lO/lO effluent in the summer and somewhat better than 30/30 

in the winter. He said the additional sophistication is 

needed to handle unusually high waste loads or waste flows 

at the treatment plant so that 30/30 effluent can be achieved 

consistently. According to EPA officials, EPA approved this 

exemption after it determined that the State criteria defining 

secondary treatment more stringently than EPA's could be met 

using conventional secondary treatment technologies. 

Revised public health requirement 

EPA modified the Appropriations Conference Committee's 

mandate that all large AWT plants must produce significant 

public health improvements to require only "mitigation of 

public health problems where they exist." 

In only one of the AWT projects we reviewed was there any 

indication that the AWT portion of the plant was intended to 

improve or safeguard public health. Present forms of AWT are 

not directed at removing substances strongly associated with 

public health problems. Additional removal of toxic 

61 
substances or disease-organisms by AWT is merely a byproduct 

rather than a principal goal of AWT. EPA officials informed 

us that public health improvements are basically accomplished 

through disinfection, not AWT. Some concern for special 

organics which may lead to cancer has been voiced, but the 

significance of such organics and the impact of AWT on them 

are unknown. 

High level of certainty 

not adequately considered 

The Appropriations Conference Committee required the EPA 

Administrator, before funding projects with an AWT increment 

over $l-million, to determine personally that the AWT will 

definitely result in significant water quality improvements. 

We recognize that absolute certainty is difficult to attain 

considering the present understanding of water quality matters. The relationship between effluent improvements and 

water quality improvements is not clear cut (see ch. 3), 

nor is the relationship between water quality characteristics 

and biological impact on uses (see ch. 2.) Nevertheless, 

we believe the Appropriations Conference Committee was 

seeking a high level of assurance of significant results 

before spending Federal funds for AWT. EPA has not always 

given this assurance before approving recent AWT projects. 

Each of the projects we looked at had some uncertainty about 

significant results. For some, it was questionable whether 

WQS could be met even after AWT was installed. FOK instance: 

--EPA approved phosphorus-removal at Rochester, 

Minnesota, although some experts said it would have no 

noticeable impact on water quality and uses. One 

expert, who has written extensively on phosphorus and 

algae in lakes and who generally believes in phosphate 

control, testified that he was uncertain whether even 

shutting down the Rochester plant entirely would make 

a difference. EPA reviewed the project and could not 

determine whether nonpoint sources would interfere 

with attaining desired beneficial uses even after AWT. 

Although it was believed that AWT would improve aquatic 

life, a fisheries official was uncertain whether new 

flood control projects will leave enough of a fishery 

to be worth protecting. 

--Federal, State, and local officials thought the AWT 

project in Walworth County, Wisconsin, would significantly improve water quality, but it was uncertain how 

many more fishermen, canoeists, and swimmers would use 

the waters as a result of the incremental treatment. 

Nonpoint source pollution and the water body's physical 
characteristics make it extremely doubtful, in our opinion, 

that AWT alone would significantly increase water use. 

EPA appears to be trying to reduce the uncertainty 

associated with AWT projects. For example, in reviewing 

the project at Leominster, Massachusetts, EPA concluded 

that modeling inadequacies left the need for sand filters 

uncertain and has refused to fund them until further 

studies can be done. The State has postponed doing 

the studies until the project is concluded and operating. 

For some other projects, EPA has deferred funding of 

filters. (See app. I.) 

THE REQUIREMENT FOR SIGNIFICANT 

WATER QUALITY IMPROVEMENT IS 

SUBJECT TO VARIOUS INTERPRETATIONS 

The phrase "significant water quality improvements" 

as used by the Appropriations Conference Committee and 

in EPA's implementing documents is ambiguous. It is not 

clear whether the term requires 

--significant (large) improvements in one or more 

water quality characteristics, with or without 

significant biological or social impact (for 

example, a 30-percent reduction in ammonia levels 

to meet the EPA-recommended criterion regardless 

of whether the number or size of fish is improved); 

--significant (large) improvements in one or more 

water quality characteristics with significant 

improvement in the designated use of the water, 

regardless of whether significant social benefits 

are attained (for example, a 30-percent reduction 

in ammonia levels that improves the number of fish 

in a minnow stream); or 

--significant (large) improvements in one or more 

water quality characteristics with significant 

positive impact on the designated use of the water 

and significant social benefits (for example, a 

30-percent reduction in ammonia levels which 

improves the number and size of fish in a reasonably accessible trout stream and leads to a significant increase in the use of the stream for 

fishing). 

Because it was not clear to us which level of 

significance EPA required, we asked EPA whether achievement 

of EPA-recommended criteria alone constitutes a significant 

63 
water quality improvement, regardless of the amount of 

incremental improvement attributable to AWT. EPA replied that 

meeting EPA-recommended criteria set to protect a particular 

designated use should allow attainment of that use and thus 

would generally improve water quality significantly. However, 

EPA also stated that for a project to be approved, the beneficial uses attained by the project must be significantly 

better than the uses attainable with lesser treatment. 

Our review identified a conflict between two EPA 

documents. EPA's implementing document (program requirements memorandum 79-7) showed that improvements in the 

designated use are specifically required only for a small 

percentage of AWT projects-- those with especially stringent 

requirements. However, EPA's final draft (June 1979) 

of the "National Municipal Policy and Strategy" suggests 

that simply permitting attainment of EPA-recommended water 

quality criteria is grounds for approving AWT. 

This conflict is supported by comments we received 

from EPA regional officials and State officials. For example, 

EPA regional officials said the filters would have been 

approved at Leominster if the model had been better, even 

though the filters only reduced BOD from 10 or 15 to 7 

my/l. The filters would have been approved because the model 

showed they were needed to meet WQS during summer droughts. 

One of the design engineers said the engineers had questioned 

the need for filters on the grounds that the small additional 

BOB reduction did not appear commensurate with the costs. 

He said the State insisted that the WQS had to be attained. 

We noted a similar situation in Wisconsin. State officials 

there informed us that any degree of water quality improvement 

would be considered significant if it would bring the 

water quality up to required standards. 

We believe it is still unclear how EPA determines 

the requirement for significant water quality improvement. 

Although the Appropriations Conference Committee does not 

address the social significance of water, we are concerned 

that EPA has stated formally that, in determining significance, it does not consider other nearby waters providing 

a similar use. 

CONFLICT BETWEEN THE CLEAN WATER 

ACT AND THE APPROPRIATIONS 

CONFERENCE COMMITTEE RESTRICTION 

The Clean Water Act establishes a national goal of 

making all waters fishable and swimmable wherever attainable 

(emphasissupplied). It requires dischargers to achieve 

whatever quality is required by the States or EPA to meet 

64 
WQS . Furthermore, the act permits the States to set overly 

stringent discharge requirements. In other words, a 

municipality may be required to build an AWT plant to prevent 

slight WQS violations predicted to occur once every 10 years 

for a brief duration in a minnow stream even though the 

standard was based on more sensitive and useful fish. In 

determining whether and how much AWT is needed, States are 

encouraged by the act to err on the side of the environment, 

to provide a margin of safety to cover any lack of knowledge 

concerning the relationship between effluent limitations 

and water quality. 

The act provides 75 percent Federal funding for 

construction of publicly owned AWT facilities required to 

meet discharge requirements imposed by States or EPA. It is 

particularly important that the act allows treatment beyond 

secondary regardless of the small degree of resulting water 

quality improvements. There is no requirement in the act 

to withhold funds for AWT if the expenditures will not result 

in a significant environmental impact. The act does not 

even require that such expenditures be directed to those 

AWT facilities that will have significant impact. Furthermore, 

there is no requirement in the act that the significance 

of WQS violations be weighed against the costs of preventing 

them. In fact, the act does not appear to allow for such 

evaluations. 

EPA regional officials summed up the situation for us 

as follows: 

--EPA has no legal basis to challenge an overly 

stringent State requirement; theoretically, a 

State could .set any "crazy“ number more stringent 

than EPA's criteria and EPA could not force the 

State to change it. 

--A single, minor standard violation once every 10 

years would be sufficient to justify a requirement 

for treatment beyond secondary. 

--EPA has no legal grounds to refuse funding for 

projects needed to attain State effluent 

limitations. 

In contrast, in approving the fiscal year 1979 

appropriation for EPA's Construction Grants Program, the 

Appropriations Conference Committee stipulated that: 

"Construction grant funds may be used for 

treatment greater than secondary only if (1) the 

incremental cost of the advanced treatment is 

$1 million or less, or (2) if the Administrator 

65 
personally determines that advanced treatment is 

required and will definitely result in significant 

water quality and public health improvements* * *." 

(Emphasis supp-d.) 

Essentially, it requires EPA to err, if necessary, on the 

side of avoiding unnecessary expenditures. 

State and EPA officials told us they believe a 

fundamental conflict exists in the congressional guidance on 

water quality. On the one hand, the Clean Water Act requires 

effluent limits that will permit achievement of WQS, whether 

or not meeting standards will definitely result in a significant water quality improvement. On the other hand, the 

Congress --through its appropriations process--has limited 

Federal funding assistance to those AWT projects which the 

EPA Administrator believes will definitely produce significant water quality and public health improvements. As a 

result, EPA has been placed in a position where it must refuse 

a community funding support for an AWT project that will not 

produce significant water quality improvement but still 

require AWT construction as necessary to achieve WQS at 

virtually all times. 

A similar conflict appears to exist within EPA. A May 

1979 report of the Association of State and Interstate Water 

Pollution Control Administrators assessed the problem as 

follows: 

"On the one hand, there is strong concern for 

stringent, relatively uniform and inflexible 

water quality standards * * *. On the other 

hand, there is growing concern within USEPA 

* * * regarding cost/benefit and cost/effectiveness considerations of the water quality 

program * * * without adequate funding AWT 

projects will not be constructed and many 

stream segments will not meet standards. 

Also without more realistic, selective and 

attainable standards, many stream segments 

will continue to attract funding for projects 

of questionable value in terms of water 

quality improvement." 

The report suggested that WQS be evaluated for cost/benefit 

relationships in specific stream segments. It argued that 

such an approach can be interpreted as addressing the 

"'wherever attainable" aspect of the national goal of fishable/ 

swimmable water. 

66 
CHAPTER 6 

CONCLUSIONS, RECOMMENDATIONS, AGENCY 

COMMENTS, AND OUR EVALUATION 

CONCLUSIONS 

Because of the difficulties associated with (1) 

designating water uses and establishing water quality 

criteria needed to protect those uses and (2) predicting 

WQS violations on the basis of mathematical modeling, AWT 

may be having little effect on water quality. Rigid 

adherence to WQS and to modeling results has been the 

basis for many questionable AWT plants. These two factors 

affect billions of dollars that have been (or will be) 

spent under EPA's Construction Grants Program. 

We noted that WQS are generally regarded as rigid 

guidelines never to be violated, and the Clean Water Act 

does not allow WQS violations--even insignificant ones--to 

occur. However, many WQS violations may not be significant 

enough to justify AWT. 

Violations may not be significant for a number of 

reasons. First, the scientific basis for the standard might 

be questionable. Our review showed that the scientific basis 

for water quality characteristics needed to protect aquatic 

life is sometimes based on limited experimental investigation. Conflicting opinions also exist on the effects of various levels of water quality on aquatic life. The American 

Fisheries Society has objected strongly to EPA's guidance on 

the water quality requirements of aquatic life. The data 

available to quantify the fishable/swimmable goal in a 

scientifically sound manner is still rather limited. Second, 

WQS violations may not be significant unless there is 

some social significance attached to them. A violation 

that impedes the use of a specific water body for swimming 

or fishing has less significance in an area of many 

fine swimming and fishing waters than it does in an area 

where such resources are limited. Third, WQS violations 

predicted by modeling are frequently highly uncertain. 

Many water quality processes cannot yet be modeled in 

a practical sense, and others can only be modeled inexactly. 

Many of naturets processes are unknown and thus too 

complicated for AWT to be justified through modeling. 

67 
When the Clean Water Act was amended in October 1972, 

apparently an assumption was made that the Federal Government 

would have sufficient funds to construct all the treatment 

projects needed to meet WQS. However, .Federal funding levels 

are not sufficient for constructing treatment projects to 

meet the fishable/swimmable goal in the foreseeable future. 

According to EPA, the cost to treat wastewater at levels 

beyond secondary in order to achieve WQS is estimated to be 

about $10 billion. 

The costs associated with wastewater treatment are 

frequently higher than the initial construction costs., When 

WQS were first established, little consideration was given 

to the costs of reaching or maintaining a given quality of 

water for a designated use. Local communities are becoming 

more concerned about the limited benefits that may be provided by AWT and are starting to question the high costs 

involved. In several instances, municipalities have gone to 

Federal court to seek relief from AWT requirements. Additional expenditures will be needed for correcting nonpoint 

pollution and other types of water pollution reduction 

programs. 

The Appropriations Conference Committee required EPA to 

ensure, before obligating its Construction Grants Program 

funds, that large AWT projects would definitely result in 

significant environmental and public health improvements. 

Our review of nine projects approved for funding by EPA 

after the requirement was imposed showed that the significance 

and/or certainty of expected improvements was questionable 

for a large number of the projects, In particular, it is 

extremely difficult to know how AWT will improve water quality 

and water uses. Relating impacts of various treatment levels 

to water quality and water uses is extremely complex and 

subjective. 

Obtaining EPA approval to reclassify WQS downward is very 

difficult and can only be done if the State can justify the 

reclassification to EPA's satisfaction. EPA resists attempts 

by States to relax (or downgrade) WQS. 

We believe the standard-setting process places too much 

emphasis on preventing all types of WQS violations rather than 

just significant violatZ%s. Until this emphasis in the law 

is changed, AWT plants,may continue to be built to prevent 

occasional and insignificant violations. Therefore, because 
--the WQS-setting process is questionable, 

--modeling to determine violations is often 

imprecise and inexact, 

--Federal funding is insufficient to achieve WQS 

for all waterways within a reasonable period of 

time, 

--obtaining downward reclassification from EPA is 

very difficult, and 

--relating the impact of various treatment levels 

on water uses is very difficult, 

we believe that AWT, with few exceptions, may not be justified 

at this time. We recognize there may be times when AWT is 

justified, such as phosphorus removal from the Great Lakes 

to comply with our Canadian treaty obligations. However, 

we conclude that funding of AWT projects should be curtailed. 

We do not believe Federal funds should be spent to provide 

a level of treatment that produces such uncertain results. 

RECOMMENDATIONS TO THE EPA ADMINISTRATOR 

We recommend that the Administrator, Environmental 

Protection Agency, take the following steps to improve the 

process of setting, revising, and implementing WQS and help 

ensure that AWT plants provide meaningful improvements to 

the Nation and the environment: 

--Become more realistic and cost conscious about the 

attainability of WQS when a State has made a reasonable 

showing that the standards are unattainable or too 

costly to attain. The Administrator should not impede 

the downgrading process with burdensome evidentiary 

requirements. 

--Reduce the cost criteria for what constitutes an 

"expensive" sewage plant. To a greater degree, the 

Administrator should accept State and local views 

that project costs are not commensurate with benefits. 

--Permit variances in reclassification criteria in cases 

where stream improvement requires treatment beyond 

secondary to meet WQS but where ecological and social 

or public health improvements are not significant 

enough to justify the costs of the improvements. 

. 
--Require EPA regions to be more consistent in 

approving variances of WQS and downgrading of WQS. 

--Require, when AWT is an issue, that at least 

two thorough surveys of the waterway be done: 

one for calibrating the mathematical model and 

another for verifying the calibrated model. 

--Develop material to help decisionmakers know the 

predictive accuracy of models used to justify AWT; 

estab*lish minimum requirements for the predictive 

accuracy of these models, 

--Establish criteria to determine the degree of 

modeling reliability that will be acceptable. 

--Develop specific criteria governing what 

constitutes an adequate and cost-effective water 

quality survey for justifying AWT projects. 

--Revise the AWT review guidelines or, if 

necessary, suggest legislative changes to allow 

revisions, to: 

1. Delete the provisions that allow projects 

not having significant water quality improvements to be funded because the projects will 

cost more if they have to be revised or 

redesigned to delete insignificant treatment 

processes. 

2. Delete the provisions that allow projects to 

be exempted from the review process if they 

involve land treatment. 

3. Delete the provisions that allow projects to 

be exempted from the review process just 

because the State's definition of "secondary 

treatment" is more stringent than EPA's. 

AGENCY COMMENTS AND OUR EVALUATION 

We sent a draft of this report to EPA for comment and 

received written comments (see app. II). 

Our draft report proposed that the Congress declare a 

moratorium and withhold funding for treatment beyond secondary 

because we believed EPA was not fully complying with the 

Appropriations Conference Committee's requirement to fund 

70 
only those projects that will definitely result in significant environmental and public health improvements. ,After 

reviewing the Agency's draft and final comments, we concluded that the best way to help the Congress resolve this 

extremely complex issue was to present a number of options 

for the Congress' consideration. Accordingly, we have 

listed several options rather than one, as we had originally 

proposed. 

EPA agreed that the Nation's water pollution program is 

costly and complex but stated that our conclusions appeared 

to reflect a misunderstanding of the legislative objectives 

established by the Congress in the Clean Water Act. EPA 

also commented that we failed to recognize States' legal 

prerogative to define their own standards, which may exceed 

Federal limitations. 

We do not believe we have misunderstood the legislative 

objectives established by the Congress nor that we have 

failed to recognize the States' legal prerogatives. We 

recognize that the Congress wanted to make "all" waters 

fishable and swimmable, but only "wherever attainable." 

Although the Congress did not require EPA to weigh the 

benefits of AWT against the costs, it did recognize that 

the fishable/swimmable goal was not attainable in all 

cases. Furthermore, EPA's regulations provide for 

States to consider "environmental, technological, social, 

economic, and institutional factors" in determining 

attainability. 

EPA said that we are inaccurate in stating that the 

costs for meeting the Congress' water quality objectives are 

not considered in the water planning process. We disagree, 

based on our discussions with State and EPA regional 

officials. According to these officials, in most cases 

States did not adequately consider costs in initial use 

designation decisions. EPA says that States are required 

to consult with their citizens when proposing stream 

use designations, WQS, and treatment systems designed 

to have discharges compatible with WQS. However, our review 

showed that while some States wanted to reduce classifications because they considered the cost to make a stream 

fishable/swimmable an excessive burden to their 

municipalities, EPA did not agree. 

EPA believes the States, in many instances, are 

adequately demonstrating that treatment beyond secondary 

(1) is needed and (2) represents a cost-effective solution 

for reducing pollutant loadings to our waterways. We do 

not agree. In its review process, EPA itself is finding 

71 
that in many instances States are not adequately demonstrating 

that treatment beyond secondary is needed. We do not contest 

that EPA's AWT project reviews have saved over $90 million. 

However, we believe that substantial additional savings could 

be realized by more careful reviews, and in this report we 

identify some important areas for improvement. We believe 

fewer AWT projects will be proposed now because of concern 

over their costs and benefits. Consequently, the AWT reviews 

have probably saved much more than $90 million. 

EPA stated that our report was based largely on an 

incomplete analysis of how it reviews AWT proposals. As a 

general practice, we cannot analyze all projects an agency 

might review. Therefore, we selected all the projects EPA 

had made final decisions on as of June 30, 1979. We had 

planned to look at more projects involving EPA's review of 

the modeling processl but EPA told us that it would take too 

much time away from its own review to respond to our requests 

for information. EPA assured us that the limited projects 

we reviewed would be typical of the other projects in its 

review process. 

EPA stated that it is prudently managing construction 

grants expenditures and is following the Appropriation Conference Committee's directives to require sufficient documentation and fund only cost-effective AWT processes. The 

committee's directive does not address cost-effectiveness; 

it addresses definite and significant improvements. As we 

point out in our report, many of the AWT projects being 

approved by the EPA's Administrator or EPA's regional offices 

are unlikely to result in definite, significant water quality 

and public health improvements. 

EPA believed that our opinion that some streams 

should not be protected from degradation because they are 

not "socially significant" concerns an area over which 

EPA cannot exercise control. We agree. We also recognize that the Clean Water Act states that all waters, regardless of location or accessibility, should be protected from 

pollution and restored, if possible, to natural conditions. 

We included a section in the report relating to the social 

insignificance of some WQS violations to identify another 

factor the Congress may want the Administrator to consider 

before approving AWT grants. The costs associated with water 

pollution cleanup are enormous, and "social significance" 

is just one factor the Congress may want to consider if at 

some future date it has to cut back the amount of funds 

devoted to water pollution control and cleanup. 

72 
We do not suggest, as EPA stated, that States should 

downgrade use designations in WQS. Nor did we conclude that 

imprecise models are being used as the basis for WQS. We 

reported that EPA makes it very difficult for States to 

downgrade use designations, and we conclude that mathematical models of water quality are often based on 

guesswork and assumptions. Questionably stringent WQS and 

dubious mathematical models have been used to justify 

expensive treatment plants that may have little effect on 

public health or environmental quality. We believe these 

matters are of interest to the Congress. 

EPA states that we appear to be advocating scant 

documentation for supporting WQS downgrading and absolute 

documentation to support efforts aimed at achieving high 

water quality. We believe that before EPA spends large sums 

of money on AWT, the evidence should be very strong that 

significant benefits will result from such treatment. States 

told us they did not know the type and extent of information 

needed to downgrade their WQS. The guidance EPA is preparing for the States, specifying what factors to include 

in justifying downgrading requests may help resolve this 

problem. 

In our draft report, we proposed that the Congress 

declare a moratorium and withhold funding for treatment beyond 

secondary because we found that EPA was not fully complying 

with the requirement set out by the Appropriations Conference 

Committee. In response, EPA pointed out that the Clean Water 

Act does not require cost/benefits analysis for AWT decisions 

and that a moratorium on AWT was incompatible with the 

explicit congressional intent to restore and maintain high 

standards of water quality nationwide. To help resolve these 

issues, we are providing several matters for the consideration 

of the Congress. 

MATTERS FOR CONSIDERATION 

BY THE CONGRESS 

We believe a cost/benefits approach to funding AWT 

projects should be seriously considered. Therefore, we are 

presenting for the Congress' consideration several alternatives which would give EPA the flexibility to consider costs 

more closely in justifying AWT projects. 

--Amend the Clean Water Act to require explicitly a 

cost/benefits review to show whether AWT will result 

in significant water quality, social, or public health 

benefits before such projects can be funded. The 

amendment should leave the WQS review process intact 

but should ensure that AWT projects are reviewed 

73 
rigorously before being funded. Thus, the 

act would allow Federal funding of projects only 

where benefits exceed costs. 

--Amend the act to require the States to do a 

cost/benefits analysis of effluent limitations more 

stringent than those required by the act. If costs 

exceed benefits, the Federal Government should not 

fund AWT for those projects. States could still 

establish mandatory effluent limitations, but 

EPA would fund projects only where a cost/benefits 

analysis justified the need for such stringent 

limitations. 

--Amend the act to declare a moratorium on AWT projects 

by withholding funding for wastewater treatment beyond 

secondary until EPA can clearly show what ecological, 

social, and public health benefits are being realized 

by the various levels of treatment beyond secondary. 

A number of AWT plants have been built and are 

operating. The Congress may want to have EPA explicity 

show what ecological, social, and public health 

benefits are being realized now that such plants 

are on line and operating. 

--Amend the act to eliminate the requirement for a 

margin of safety which compensates for the lack of 

knowledge concerning the relationship between 

effluent limitations and water quality and include 

language in the act to require that all treatment 

beyond secondary and costing $1 million or more must 

produce significant ecological and social or public 

health improvements. This change of emphasis should 

promote wiser investments in AWT facilities. 

74 
RECAP OF IMPORTANT MODELING CONSIDERATIONS 

FOR SELECTED AWT PROJECTS PROPOSED FOR 

THE ADMINISTRATOR’S APPROVAL li 

Modeling Considerations Task Force Actbns 

Gid the model 

Incremental separately consider Were there water 

nonpoint sources qualiw standard 

pollution? violations at high flow? 

Were nighttime Was the time Was a second 

DO m&y5 of travel survey taken for Tvw of 

meCW,Rd? verification ur xs? actlo” -- Savingr 

Period 

mod&d 

Walworth County. WISC $ 20.0 

Leormnstcr. Mass. . 19.3 

Brockto” Mass 16.9 

YES 

Yes 

YE3 

Yes 

Yes 

NO 

Yes 

YRS 

NO 

NO NO 

NO No 

NO NO 

NO NO 

Yes Yes 

Yes 6 Yes 6 

No 3 No 4 

$ 4.0 

2.8 

9.7 

NO 

Yes 

NO 

Summer only 

SumrrrerlWinler 

Summer only 

waupun. WEC 5.5 1.9 NO NO Summer only 

Muden, Corm 28.8 5.3 NO NO Summer only 

Manasquan, N.J 16.4 1.2 NO Unknown Summer only 

Portage, Ind. 66 

“alparam. Ind 119 

Sou,x Falls. S Dak 49.1 

Albert Lea, Mann 20.0 

Rochester. N.H. 7.6 

2.6 

2.9 

94 

4.0 

2.3 

- 

NO 

NO 

NO 

Yes 

No 

Yes 1 

No lQ 

NO 

NO 

Yes 

YRS 

No 

Yes 3 

NO 7 

Unknown 1 

z 

Summer only 

Summer only 

Summer/Winter 

Summer/Winter 

Summer only 

Summer only 6 

SummerlWmter_3 

TOTAL $2021 $46.1 11 = 

YES 

Yes 

Yes 

Yes 

NO 

NO 

” 

Defer folterr. nttr~ficanon. 

& chlormanon 20 

Approved 

Capacity reduced 

Defer f,lters 

& lnterceptorr 

Defer ftlters 

35 

33 

06 

No 

NO 

ri0 

NO 

No 

Yes 4 

Approved 

Defer filters 13 

- 

No 1 

11 $l& = 11 

= 
APPENDIX II APPENDIX II 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

FEB 5, 1980 

OFFICE OF 

PLANNING AN0 MANAGEMENT 

Mr. Henry Eschwege 

Director 

Community and Economic Development Division 

United States General Accounting Office 

Washington, D.C. 20548 

Dear Mr. Eschwege: 

We have reviewed the General Accounting Office's draft report, 

"Many Water Quality Standard Violations May Not Be Significant Enough to 

Justify Costly Preventive Actions." The opinion, expressed in the report, 

that the nation's water pollution control program is costly and complex 

is unassailable. The report's conclusions, however, appear to reflect 

a misunderstanding of the legislative objectives established by Congress 

in the Clean Water Act, and the primary recommendation fails to recognize 

the legal prerogative of states to define standards for protection of 

their waters which may exceed federal limitations. Congress clear&y said 

federal water quality objectives are the minimum required, and that States 

may adopt more stringent standards of protection. We support the need for 

State discretionary authority in this area. 

Recommendations calling for a moratorium on funding all variations 

of wastewater treatment beyond secondary are incompatible with the explicit 

Congressional intent to restore and maintain high standards of water quality 

nationwide. The report states the costs for meeting Congress' water quality 

objectives are not considered in the water planning process. This is 

inaccurate and moreover ignores the process by which States are required 

to consult with their citizens when proposing stream use designations, 

water quality standards, and treatment systems designed to have discharges 

compatible with water quality standards. 

In many instances the States are adequately demonstrating that 

treatment beyond secondary is needed and represents a cost effective 

solution for reducing pollutant loadings to our waterways. EPA is screening 

State proposals seeking funding for advanced wastewater treatment processes. 

Our screening initiatives follow the directives established by the 

Appropriations Committees, and the review has resulted in considerable 

savings to the Federal Government and to local taxpayers that would have 

paid higher treatment plant operating costs had unneeded AWT proposals 

been funded. 
APPENDIX II APPENDIX II 

The GAO report, based largely on an incomplete analysis of how AWT 

proposals are being reviewed by EPA, fails to note that we deleted or 

deferred funding for 23 out of 50 AWT proposals submitted by the States 

for review through December 31, 1979. After thorough analysis of these 

23 projects we determined that sufficient documentation was not presented 

showing AWT processes were needed to meet water use designations. These 

AWT systems were not funded as proposed, saving $90.2 million in unneeded 

expenditures. We are now reviewing twenty-four additional AWT proposals. 

We believe that a complete analysis of our funding determinations shows 

EPA is prudently managing construction grant expenditures and is following 

the Appropriations Committees' directives to require sufficient documentation 

and fund only cost effective AWT processes. 

We agree with the report's conclusion that the water quality planning 

process is complex, and that the maximum benefit should be sought for 

each water pollution control dollar spent. The opinion advanced, however, 

that some streams should not be protected from degradation because they 

are not "socially significant" is not a discretionary area for administrative 

determination. Congress clearly states in the Clean Water Act that all 

waters, regardless of location or accessability, should be protected 

from pollution and restored, i f possible, to natural conditions. We 

agree with this Congressional determination to restore and maintain the 

quality of all of the nation's waters and have designed the national 

water quality regulatory strategy to achieve these national objectives 

as defined by Congress. Further, we must take serious exception with a 

GAO report which seems to be aimed primarily at excoriating the Agency 

for a faithful interpretation and implementation of federal law. 

The draft report suggests EPA should ignore the Congressional objectives 

as defined in the Clean Water Act and encourage States to downgrade use 

designations and water quality standards. This position is supported by 

GAO's conclusion that imprecise models are being used as the basis for 

water quality standards, and that models are not a valid basis for 

determining effluent limitation requirements. Few models, even very 

expensive and refined models, can absolutely duplicate a complex natural 

system and conclusively predict how man's activities affect that system 

over time. Ample analytical techniques exist, however, and sufficient 

information is available to make informed judgments. All scientific 

opinions include a degree of uncertainty, and scientists will interpret 

the same data differently. In our water program we question the reliability 

of both modeling and scientific opinion, and the agency makes every 

effort to assure both are reasonably accurate. 

The draft report's conclusion, however, that the agency's process for 

approving water quality downgradings is too rigorous seems incompatible 

with the point advanced on modeling. EPA has a policy on downgradings, 

and additional guidance is being prepared for use by the States which will amplify 

what factors must be considered so downgrading requests are adequately and 
APPENDIX II APPENDIX II 

successfully justified. Generally, our policy requires that States 

demonstrate designated water uses and established water quality standards 

cannot be achieved because of economic hardships, natural conditions, or 

'irreversible man-induced activities. Models are useful to States trying 

to meet these requirements, but they must be documented. 

GAO appears to be advocating that we require scant documentation for 

supporting water quality downgradings and absolute documentation to 

support efforts aimed at achieving high water quality. Our position is 

to require adequate documentation to support both water quality downgradings 

and efforts to improve water quality. Eight States have sought water 

quality standard or stream use designation downgradings within the past 

two years. EPA found in one case that adequate justification was presented 

to approve the downgrading request, and we are reviewing the seven other 

downgrading requests. EPA will continue to review water quality standards 

and stream use designations, but the Clean Water Act requires we strive 

for high water quality within limits of natural conditions. 

We appreciate the opportunity to corrment on the draft report. 

for Planning and Management 

(089010) 

78 
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