Office of Inspector General 

Audit Report 

WATER 

Missouri’s Water Quality Standards and Monitoring

Report No. E1HWF7-07-0023-8100080

March 31, 1998
Inspector General Division Central Audit Division

 Conducting the Audit: Kansas City, Kansas

Region Covered: Region 7

Program Office Involved: Water, Wetlands, and Pesticides Division
March 31, 1998

MEMORANDUM

SUBJECT: Missouri’s Water Quality Standards and Monitoring

Audit Report E1HWF7-07-0023-8100080

FROM: Bennie S. Salem

Divisional Inspector General

TO: Dennis Grams

Regional Administrator

Region 7

Attached is our report entitled Missouri’s Water Quality Standards and Monitoring. The

report includes recommendations that Region 7 require Missouri to adopt the “swimmable” use

classification, where it can be achieved, and adopt Environmental Protection Agency (EPA) or

scientifically defensible criteria. Missouri needs to develop a monitoring strategy and

management plans to comprehensively assess the quality of its waters. In addition, Missouri

should ensure its water quality reports are complete and accurate. We discussed our findings with

your staff and issued a draft report. We summarized your comments in the final report and

included your complete response in Appendix I. Missouri concurred with our recommendations,

but did not provide a written response in time to be included in this report. 

ACTION REQUIRED

In accordance with EPA Order 2750, you, as the action official, are required to provide

this office a written response to the audit report within 90 days of the final audit report date. For

corrective actions planned but not completed by the response date, reference to specific milestone

dates will assist in deciding whether to close this report. 

We appreciate the cooperation your staff provided throughout the audit. We especially

appreciate the program staff's assistance and timely response during the audit. The staff exhibited

a genuine interest in working with us to improve the water quality program. The staff recognized

from the beginning that this audit would provide the basis for similar audits of other states, and

worked closely with us to ensure we had a comprehensive understanding of Region 7's water

quality program. The staff's efforts helped add value to this audit and to our planned national

program audits. 
This audit report contains findings that the Office of Inspector General (OIG) has

identified and corrective actions OIG recommends. This audit report represents the opinion of

OIG, and the findings in this audit report do not necessarily represent the final EPA position. 

Final determinations on matters in this audit report will be made by EPA managers in accordance

with established EPA audit resolution procedures. 

We have no objections to the release of this report to the public. 

If you have any questions, please call me at (913) 551-7831 or Connie Walton, Audit

Manager, at (913) 551-7007. Please refer to report number E1HWF7-07-0023-8100080 on any

correspondence.

Attachment
E1HWF7-07-0023-8100080

i

Missouri’s Water Quality Standards and Monitoring

EXECUTIVE SUMMARY

INTRODUCTION People use lakes, rivers, and streams for drinking water,

boating, fishing, swimming, irrigation, and industry. States

adopt water quality standards to protect these uses of the

water, and monitor the water to find out how well the water

quality supports the water uses. States and the

Environmental Protection Agency (EPA) use the water

quality information as a basis for their programs to control

and clean up water pollution. We selected Missouri because

Office of Water personnel suggested several states,

including Missouri, where audits could identify best

practices and needed improvements in the states' programs

to develop standards and monitor and report on water

quality. 

OBJECTIVES Our overall objective was to review Missouri's water quality

standards and monitoring program. Our specific audit

objectives were to answer the following questions: 

C Has Missouri implemented procedures to

develop water quality standards that will

protect its water quality? 

C Has Missouri implemented procedures to test

and assess the quality of all appropriate

waters in the State?

C Are State reports on water quality complete,

accurate, and useful for program

management?

C Has Region 7 implemented effective

procedures to approve Missouri’s water
Missouri’s Water Quality Standards and Monitoring

E1HWF7-07-0023-8100080

ii

quality standards and evaluate the State’s

water quality standards setting, testing,

assessing, and reporting?

RESULTS IN BRIEF Missouri took significant action to protect and monitor its

water quality in conjunction with Region 7 oversight;

however, Missouri could benefit from some improvements. 

Missouri needed to establish water quality standards that

will protect water quality at the level envisioned by the

Clean Water Act. Additionally, Missouri needed to design

its water quality testing to comprehensively assess the

quality of its waters. Missouri could improve its procedures

to ensure that its water quality reports are complete and

accurate. Region 7 needed to review and approve

Missouri's water quality standards. Further, Region 7

needed to better tie Missouri's use of available water quality

management tools to the grant funds provided by Region 7. 

Several Missouri Water

Quality Standards Were

Less Restrictive Than

National Targets

Most of Missouri's standards to protect its water quality

met EPA requirements; however, several of Missouri's

standards were less restrictive than those required by the

Clean Water Act. Missouri did not adopt the national

“swimmable” use classification for all of its waters, and did

not conduct the required studies to show the “swimmable”

use was unachievable for waters not classified as

swimmable. Missouri did not ensure that the use

classifications reflected the actual water use. The State

could not demonstrate that water quality criteria that were

less restrictive than EPA's criteria would protect the water

uses. Further, Missouri did not adopt procedures to

maintain and protect water quality. As a result, Missouri

did not ensure that all of its waters were as clean as

intended by the Clean Water Act. 

Missouri's Process to Test

and Assess Water Quality

Could Be Improved

Missouri made a good effort to monitor its water quality,

but could improve its process to test and assess its waters. 

Missouri did not have a strategy to comprehensively
Missouri’s Water Quality Standards and Monitoring

E1HWF7-07-0023-8100080

iii

evaluate all its waters. Missouri made water quality

assessments without appropriate test results. Also,

Missouri needed to update its water quality management

plans to communicate changing priorities. As a result,

Missouri did not know the quality of all of its waters and

did not have a plan to find out. 

Missouri Should Have

Procedures for Complete

And Accurate Water 

Quality Reporting

Missouri’s reporting procedures did not ensure its water

quality reports were complete and accurate. Missouri

excluded assessments it made of intermittent streams from

its 1996 water quality assessment reports and did not retain

a list of specific waters included in summary tables in the

report. Further, Missouri did not always ensure the

accuracy of the information in its water quality data

systems. As a result, Missouri did not comprehensively

report on its water quality. EPA uses information from

state water quality assessment reports to measure state

performance in protecting and maintaining water quality. 

Region 7 Should Improve

Oversight and Technical

Assistance for Missouri's

Water Quality Programs

Region 7 could have provided better technical assistance

and oversight to ensure that Missouri had an adequate basis

for its water quality programs. Region 7 did not fulfill its

responsibility to approve Missouri's water quality standards;

however, the Region committed to timely approval actions

in its fiscal 1998/1999 regional management agreement. 

The Region did not require as a grant condition that

Missouri use available water quality planning tools. Also,

the Region approved Missouri's impaired waterbody list

without confirming the list was complete. As a result, the

Region could not be sure Missouri protected its water

quality as envisioned by the Clean Water Act. 

RECOMMENDATIONS We recommend that the Regional Administrator require

Missouri to adopt the “swimmable” use classification where

it can be achieved or conduct the required studies to show

the use cannot be achieved. The Region should require

Missouri to adopt EPA or scientifically defensible criteria. 
Missouri’s Water Quality Standards and Monitoring

E1HWF7-07-0023-8100080

iv

The Region should request that Missouri develop a

monitoring strategy and management plans to ensure

Missouri comprehensively assesses the quality of its waters. 

In addition, the Region should request that Missouri

implement procedures and controls to ensure its water

quality reports are complete and accurate. The Region

should timely review and take prompt action on the State's

water quality standards. Also, the Region needs to require

supporting information for Missouri's impaired waterbody

list. 

AGENCY COMMENTS Region 7 generally agreed with the findings and

recommendations. The Region provided comments to

clarify portions of the report, and we have incorporated

these comments and modified the report as appropriate.

Missouri concurred with our recommendations, but did not

provide a written response in time to be included in this

report. We will provide a copy of Missouri's response upon

request. 
Missouri’s Water Quality Standards and Monitoring

E1HWF7-07-0023-8100080

v

TABLE OF CONTENTS

Page

EXECUTIVE SUMMARY ................................................... i

ABBREVIATIONS ........................................................ vii

CHAPTERS 

1 INTRODUCTION ..................................................... 1

Purpose ....................................................... 1

Background .................................................... 2

Scope And Methodology .......................................... 5

Prior Audit Coverage ............................................. 5

2 SEVERAL MISSOURI WATER QUALITY STANDARDS WERE LESS 

 RESTRICTIVE THAN NATIONAL TARGETS ............................. 6

Background .................................................... 6

Missouri Did Not Adopt The National Water Quality

 “Swimmable” Use Classification For All Applicable 

 Waterbodies .................................................. 7

Missouri Needed to Protect Actual Water Uses ......................... 8

Missouri Adopted Criteria That Were Less Protective

 Than National Criteria ........................................... 8

Missouri Did Not Adopt Its Antidegradation

 Implementation Procedures ...................................... 10

Conclusion .................................................... 11

Recommendations .............................................. 11

Auditee Comments and OIG Evaluation .............................. 12

3 MISSOURI'S PROCESS TO TEST AND ASSESS WATER QUALITY 

 COULD BE IMPROVED ............................................. 13

Background ................................................... 13

Missouri Needed to Better Plan Its Water Quality 

 Monitoring .................................................. 14

Missouri Assessed Water Quality Without 

 Appropriate Testing Results ..................................... 16

Missouri Did Not Update Water Quality Management

 Plans ....................................................... 17
Missouri’s Water Quality Standards and Monitoring

E1HWF7-07-0023-8100080

vi

Conclusion .................................................... 17

Recommendations .............................................. 18

Auditee Comments and OIG Evaluation .............................. 18

4 MISSOURI SHOULD HAVE PROCEDURES FOR COMPLETE 

 AND ACCURATE WATER QUALITY REPORTING ....................... 19

Background ................................................... 19

Missouri Excluded Assessments of Intermittent Streams

 From Its Water Quality Assessment Report .......................... 20

Missouri Could Not Identify Specific Waters Included 

 In Its Water Quality Report ...................................... 21

Missouri Could Not Justify Exclusion of Impaired Waterbodies

 From the Impaired Waterbody List ................................ 21

Missouri Did Not Have Procedures to Ensure Data 

 Systems Were Complete And Accurate ............................. 22

Conclusion .................................................... 23

Recommendations .............................................. 24

Auditee Comments and OIG Evaluation .............................. 25

5 REGION 7 SHOULD IMPROVE OVERSIGHT AND TECHNICAL ASSISTANCE

 FOR MISSOURI'S WATER QUALITY PROGRAMS ....................... 26

Background ................................................... 26

Region 7 Did Not Approve Missouri's Water Quality 

 Standards .................................................... 27

Region 7 Did Not Require Missouri to Use Water 

 Quality Management Tools ...................................... 29

Region 7 Approved Missouri’s Impaired Waterbody 

 List Without Ensuring It Was Complete ............................. 31

Conclusion .................................................... 31

Recommendations .............................................. 32

Auditee Comments and OIG Evaluation .............................. 32

EXHIBITS

1 SCOPE AND METHODOLOGY ........................................ 33

2 LESS RESTRICTIVE CRITERIA IN MISSOURI’S 1996 WATER 

 QUALITY STANDARDS ............................................. 35
Missouri’s Water Quality Standards and Monitoring

E1HWF7-07-0023-8100080

vii

3 POLLUTANTS LIMITED IN PERMITS AND

 NOT IN WATER QUALITY STANDARDS ............................... 36

APPENDICES

I EPA RESPONSE .................................................... 37

II DISTRIBUTION ..................................................... 42
Missouri’s Water Quality Standards and Monitoring

E1HWF7-07-0023-8100080

viii

ABBREVIATIONS

CFR Code of Federal Regulations

EPA Environmental Protection Agency

OIG Office of Inspector General

STORET STOrage and RETrieval

TMDL Total Maximum Daily Loads

303(d) List Impaired Waterbody List

305(b) Report Water Quality Assessment Report
E1HWF7-07-0023-8100080

1

Missouri’s Water Quality Standards and Monitoring

CHAPTER 1

INTRODUCTION

PURPOSE People use lakes, rivers, and streams for drinking water,

boating, fishing, swimming, irrigation, and industry. States

adopt water quality standards to protect these water uses,

and monitor the water to find out how well the water

quality supports the uses. States and the Environmental

Protection Agency (EPA) use their water quality

information as a basis for, and to measure performance of,

their programs to control and clean up water pollution. We

selected Missouri because Office of Water personnel

suggested several states, including Missouri, where audits

could identify best practices and needed improvements in

the states' programs to develop standards and monitor and

report on water quality. 

Our overall objective was to review Missouri's water quality

standards and monitoring program. Our specific objectives

were to identify the following:

C Has Missouri implemented procedures to

develop water quality standards that will

protect its water quality? 

C Has Missouri implemented procedures to

test and assess the quality of all appropriate

waters in the State?

C Are State reports on water quality complete,

accurate, and useful for program

management?

C Has Region 7 implemented effective

procedures to approve Missouri’s water

quality standards and evaluate the State’s

water quality standards setting, testing,

assessing, and reporting?
Missouri’s Water Quality Standards and Monitoring

E1HWF7-07-0023-8100080

2

BACKGROUND The Clean Water Act is the primary legislation addressing

water quality programs. The Act’s objective is to restore

and maintain the quality of the nation’s surface waters. The

Clean Water Act requires states to adopt water quality

standards. These standards are an important basis for state

actions to control and remedy water pollution. Water

quality standards have three parts: water use classifications,

water quality criteria, and an antidegradation policy. 

States classify the state waters according to how the water

can be used, such as for drinking water supply, fishing, and

swimming. The waters can have multiple use classifications. 

The Clean Water Act goal is that all waters of the United

States will be “fishable, swimmable” where attainable. The

“fishable” goal provides for the protection and propagation

of fish, shellfish, and wildlife. The “swimmable” goal

provides for recreation in and on the water. States are

required to adopt “fishable, swimmable” use classifications

for all their waters, unless they can show that the water

could not sustain these uses. States can adopt additional

use classifications, such as boating, drinking water supply,

and agricultural or industrial use. 

Once the water use classification is set, the Act requires the

state to develop water quality criteria for that use. Water

quality criteria identify conditions that sustain the water use,

such as the amount of a specific pollutant that may be

present in the water, or the biological or physical condition

of the water. For example, the water quality criteria for a

“swimmable” use could identify how much fecal coliform

can be present in the water and allow safe swimming. 

EPA publishes criteria that set numerical limits for

pollutants based on the effect the pollutants have on the

water use classifications. The Clean Water Act required

EPA to develop criteria for and designate 126 chemicals as

“priority” toxic pollutants; i.e., the most persistent,

prevalent, and toxic of chemicals. EPA has developed

criteria for 99 “priority” toxic pollutants and 30 other
Missouri’s Water Quality Standards and Monitoring

E1HWF7-07-0023-8100080

3

pollutants. The states may use EPA's criteria or develop

their own scientifically defensible criteria. 

Title 40, Code of Federal Regulations (CFR) part 131.12

requires states to have an antidegradation policy to

conserve, maintain, and protect existing uses of waterbodies

and maintain water quality. The antidegradation policy also

should protect waters of exceptionally high quality or value.

States are required to review their water quality standards

once every 3 years and obtain EPA approval for the

standards. EPA is required to promulgate water quality

standards for the state if EPA disapproves a state’s water

quality standards. The state’s water quality standards

remain in effect unless EPA promulgates standards for the

state. 

CFR part 130.4, Water quality monitoring, requires the

states to develop a monitoring program to assess whether

the state’s waters meet the water quality standards. The

state water quality monitoring program generates important

information necessary to guide management decisions and

track environmental progress. The monitoring program

identifies the waters to be tested, the frequency of testing,

the types of testing, and the entity to conduct the testing. 

The state monitoring program must meet EPA’s general

quality assurance requirements. 

The Clean Water Act requires each state to submit to EPA a

biennial water quality assessment report (305(b) report)

summarizing its water quality assessments. EPA

summarizes the state reports in a national report to

Congress. EPA uses the state water quality assessments to

measure performance in achieving its goal of clean and safe

water. 

If a waterbody does not meet its water quality standards,

the state classifies the waterbody as impaired and

determines the cause of impairment. Water pollution comes
Missouri’s Water Quality Standards and Monitoring

E1HWF7-07-0023-8100080

4

from either point or nonpoint sources. Point source

discharges are controlled through the use of permits. 

Examples of point source dischargers are municipal sewage

treatment plants and industrial facilities. These types of

facilities discharge through identifiable conveyances, such as

pipes or sewers into surface waters. Nonpoint sources of

pollution are diffuse and less readily identifiable, such as

polluted runoff from agriculture. 

Once the state identifies its impaired waterbodies, the state

is required to develop total maximum daily loads if existing

controls are not sufficient to correct the impairment. Total

maximum daily loads specify the amount of pollution

allowed to enter a waterbody from both point and nonpoint

sources. The Clean Water Act requires the state to submit

to EPA a biennial list of its impaired waterbodies (303(d)

list) that will require total maximum daily loads. EPA

reviews and approves the impaired waterbody list and all

state total maximum daily loads. 

The Missouri Clean Water Commission and the Missouri

Department of Natural Resources are responsible for

protecting and maintaining Missouri's water quality. In

fiscal 1998, EPA provided grants to the Department of

Natural Resources of approximately $2.7 million for its

water pollution control programs. The Clean Water

Commission sets pollution control policy in Missouri. The

Water Pollution Control Program within the Department of

Natural Resources is responsible for advising the

Commission on water quality standards, monitoring water

quality, and compiling the testing data from all sources into

its water quality information system. The Water Pollution

Control Program then assesses whether the individual

waterbodies meet the state water quality standards. 

Missouri's 1996 water quality assessment report concluded

that 47 percent of its stream miles and 15 percent of its lake

acres were impaired. The waters were impaired mainly
Missouri’s Water Quality Standards and Monitoring

E1HWF7-07-0023-8100080

5

from agricultural sources, such as soil erosion and

herbicides, or from natural sources.

SCOPE AND

METHODOLOGY

We performed our audit in accordance with the Government

Auditing Standards (1994 revision) issued by the

Comptroller General of the United States as they apply to

program audits. Our review included tests of the program

records and other auditing procedures we considered

necessary. We conducted our fieldwork from July through

December 1997. We performed our fieldwork at Region 7

in Kansas City, Kansas, and at Missouri Department of

Natural Resources in Jefferson City, Missouri. 

See Exhibit 1 for scope and methodology details.

PRIOR AUDIT

COVERAGE

Neither the Office of Inspector General (OIG) nor the U.S.

General Accounting Office issued any recent reports directly

related to Missouri's water quality standards and

monitoring. 
E1HWF7-07-0023-8100080

6

Missouri’s Water Quality Standards and Monitoring

CHAPTER 2

SEVERAL MISSOURI WATER QUALITY STANDARDS WERE 

LESS RESTRICTIVE THAN NATIONAL TARGETS

Most of Missouri's standards to protect its water quality met

EPA requirements; however, several of Missouri's standards

were less restrictive than those required by the Clean Water

Act. The Clean Water Act requires every state to establish

water quality standards, including use classifications,

criteria, and procedures to maintain and protect water

quality. Missouri did not adopt the national “swimmable”

use classification for all of its waters and did not have

adequate procedures to ensure that the use classifications

reflected actual uses. The State did not always adopt water

quality criteria that were as protective as national criteria. 

Further, Missouri did not adopt antidegradation

implementation procedures to maintain and protect water

quality. As a result, Missouri did not ensure that all of its

waters were as clean as intended by the Clean Water Act. 

BACKGROUND CFR part 131.10, Designation of uses, requires every state

to adopt “fishable, swimmable” use classifications for every

waterbody, or else demonstrate why the uses cannot be

achieved. If the state does not adopt the “fishable,

swimmable” use classifications, the state must conduct a

study to determine if the “fishable, swimmable” use

classifications are not achievable. The state may establish

use classifications that have not actually been achieved for

the waterbody at the time it establishes the uses. 

CFR part 131.11, Criteria, requires states to adopt water

quality criteria based on sound science for any pollutants

which may be present in the waters and negatively impact

the state use classifications. The regulation does not limit

the requirement to the “priority” toxic pollutants. States
Missouri’s Water Quality Standards and Monitoring

E1HWF7-07-0023-8100080

7

can establish criteria based on EPA-published criteria, or 

develop criteria based on scientifically defensible methods. 

CFR part 131.12, Antidegradation policy, requires the state

to develop methods to implement its antidegradation policy. 

State antidegradation policies and implementation

procedures are subject to EPA review.

MISSOURI DID NOT

ADOPT THE NATIONAL

WATER QUALITY

“SWIMMABLE” USE

CLASSIFICATION FOR

ALL APPLICABLE

WATERBODIES

Missouri did not classify 75 percent of its significant streams

and 11 percent of its lakes as “swimmable” and did not

conduct the required studies to justify that the “swimmable”

use classification was not achievable. The Clean Water Act

required every waterbody to be “swimmable,” where

attainable. As a result, Missouri did not protect the lakes

and streams from bacteria that can be harmful for human

health.

Missouri did not adopt the “swimmable” use classification

for all its waterbodies. State officials said that the waters

were not classified as “swimmable” because physical

conditions made them unattractive for swimming. For

example, Missouri officials said that most streams in north

Missouri are not classified as swimmable because they are

muddy. However, EPA's Water Quality Standards

Handbook states that physical factors alone do not

adequately justify not adopting a “swimmable” use

classification.

Furthermore, Missouri did not conduct the required studies

for these waterbodies. Missouri officials said they were

unaware of the study requirements. However, in a letter

dated November 29, 1993, Region 7 informed Missouri that

the studies were required. We reviewed a sample of 60

waterbodies including 44 waterbodies that were not

classified as “swimmable,” and Missouri had not conducted

the required studies for any of the 44 waterbodies. 
Missouri’s Water Quality Standards and Monitoring

E1HWF7-07-0023-8100080

8

MISSOURI NEEDED TO

PROTECT ACTUAL

WATER USES

Missouri’s procedures for identifying changes in water uses

did not ensure that the actual water uses were adopted. The

Clean Water Act requires each state to establish water

quality standards that consider the waters' use and value for

public water supplies and other purposes. Missouri

encouraged and generally considered comments on the

public's uses of lakes and streams. However, it did not have

a procedure to list comments received and track whether the

comments were considered for use classifications in the

triennial review of water quality standards. Without such a

process, critical information can be lost. 

For example, we reviewed a sample of 60 waterbodies and

found Missouri was notified that 1 stream was used for

drinking water supply, but Missouri did not adopt the use in

its next triennial review. Missouri officials agreed that the

drinking water use classification should be adopted for the

stream. However, Missouri did not have a process in place

to ensure all its waterbodies were classified and protected

for their actual uses. 

MISSOURI ADOPTED

CRITERIA THAT WERE

LESS PROTECTIVE

THAN NATIONAL

CRITERIA

Missouri established water quality criteria that applied

generally to all its waters for a given use classification;

however, several criteria were less protective than national

criteria set by EPA. EPA has developed criteria for 99

“priority” toxic pollutants and 30 other pollutants. Missouri

adopted less restrictive criteria for eight “priority” toxic

pollutants and six nonpriority pollutants, and did not

provide scientific justification for the less restrictive criteria. 

Missouri did not demonstrate that the designated uses

would be protected with the less stringent criteria, or that

the pollutants were not present in the State. Also, Missouri

did not adopt criteria for all known pollutants discharged in

its waters. As a result, Missouri allowed more of these

pollutants to be present in its waters before it considered

them a threat to the water quality. 
Missouri’s Water Quality Standards and Monitoring

E1HWF7-07-0023-8100080

9

Exhibit 2 shows the 14 pollutants and use classifications

where Missouri’s criteria were less restrictive, along with

the following explanations Missouri provided: 

C Four pollutants--Missouri did not provide an

explanation for why it did not adopt EPA criteria,

although Missouri told us it would adopt the criteria

in its next review. 

C Three pollutants--Missouri stated that it did not

adopt EPA criteria or adopted less restrictive criteria

because naturally occurring concentrations

prevented the State from adopting EPA criteria. 

However, even if natural background levels exceed

the national criteria limits, CFR part 131.11 requires

the state to identify site-specific criteria where

natural background levels are higher.

C One pollutant--Missouri did not adopt EPA criteria

because it stated implementing EPA’s criteria across

the State would be too expensive. However, EPA

allows the State to conduct studies to identify if the

criteria are not necessary for specific waterbodies. 

C Two pollutants--Missouri stated it did not adopt

EPA criteria because it was unaware of current EPA

criteria.

C One pollutant--Missouri adopted less restrictive

criteria because it used outdated EPA criteria. 

C Three pollutants--Missouri did not adopt EPA

criteria and adopted less restrictive criteria, but did

not provide an explanation to us. 

In November 1993, Region 7 notified Missouri that more

restrictive criteria were required for 12 of the 14 pollutants, 

as a result of the Region’s review of Missouri's proposed

1994 water quality standards. In February 1994, Missouri

told the Region it would adopt criteria for 4 of the 12

pollutants in its next water quality standards review, but had

not done so for its 1996 water quality standards. For the

remaining eight pollutants, Missouri provided similar

explanations to the Region as above. 
Missouri’s Water Quality Standards and Monitoring

E1HWF7-07-0023-8100080

10

Missouri only adopted criteria for pollutants for which EPA

published criteria, even though Missouri limited other

pollutants in its water quality permits. Missouri did not

have procedures in place to identify pollutants discharged in

the permits and consider if the pollutants should be limited

in the water quality standards. Missouri did not have a

process to identify the impact on receiving waters and the

number of permits affected by these pollutants. We

reviewed 30 permits and found 9 pollutants, such as

nitroglycerin and phosphorous, that were restricted in the

permits but were not included in Missouri’s water quality

standards. These pollutants are listed in Exhibit 3. As a

result, Missouri does not monitor and report on the effect of

these pollutants on the receiving water. Missouri said its

Clean Water Commission was reluctant to adopt criteria in

the absence of EPA-published criteria and had the

philosophy that if EPA did not establish criteria, it was not

necessary for Missouri to do so. 

MISSOURI DID NOT

ADOPT ITS

ANTIDEGRADATION

IMPLEMENTATION

PROCEDURES

Missouri did not have approved antidegradation

implementation procedures. CFR part 131.12,

Antidegradation policy, requires states to develop

implementation procedures to maintain and protect higher

quality waters. The regulation identifies two levels of

higher quality waters. Missouri has implemented

procedures to protect its highest quality waters; however,

Missouri had not implemented its draft procedures to

protect the second level of high quality waters. Missouri

drafted implementation procedures in 1994, but did not

finalize and adopt the procedures. Missouri did not conduct

antidegradation reviews to identify and protect the second

level of high quality waters as provided in the procedures. 

Without these procedures, Missouri cannot ensure that it

consistently identifies and protects its higher quality waters. 

State and Region 7 officials said that Region 7 informally

notified Missouri that implementation procedures were

required, but Region 7 did not document any formal
Missouri’s Water Quality Standards and Monitoring

E1HWF7-07-0023-8100080

11

comments to Missouri on its draft implementation

procedures.

CONCLUSION While Missouri took action to protect its water quality

through its water quality standards, it needed to strengthen

its efforts. Missouri's use classifications and criteria did not

protect water quality at the level set by the Clean Water Act

and national criteria. Missouri's water quality standards

serve as the foundation for its approach to pollution control

and water quality management. If Missouri does not adopt

national criteria, it should explain its reasons and ensure its

criteria are based on sound science. Otherwise, Missouri

cannot be sure that the pollutant levels it allows in its waters

will not threaten human health or aquatic life. 

RECOMMENDATIONS We recommend that the Regional Administrator:

2.1 Work with Missouri and provide technical

assistance to schedule the necessary studies to

identify if the “swimmable” use classification

could be achieved for waterbodies where

Missouri has not adopted this use. 

2.2 Request that Missouri establish a procedure to

track comments received on actual uses, and

ensure they are considered in changing water use

classifications.

2.3 Review Missouri's water quality standards to

determine if Missouri has a scientifically

defensible basis for criteria that are less

restrictive than EPA-published criteria and take

appropriate action to disapprove any criteria that

are not scientifically defensible. Provide 
Missouri’s Water Quality Standards and Monitoring

E1HWF7-07-0023-8100080

12

technical assistance to help the State develop

scientifically defensible criteria, if appropriate.

2.4 Work with Missouri to ensure the State adopts

the water quality criteria for the four pollutants it

agreed to adopt by the next water quality

standards review.

2.5 Request Missouri to adopt an antidegradation

implementation policy that supports the intent of

the Clean Water Act. Request that Missouri

document its antidegradation reviews and

identify and protect the second level of high

quality waters. 

AUDITEE COMMENTS

AND OIG EVALUATION

Region 7 generally agreed with the findings and

recommendations. The Region provided comments to

clarify portions of the report, and we have incorporated

these comments and modified the report as appropriate. 

Region 7 stated Missouri's omission of a scientificallydefensible justification for its criteria is a more critical issue

than the number of less protective criteria, because without

such justification the Region cannot conclude that the

criteria are adequate, nor can it conclude that the criteria are

unprotective. Region 7 emphasized, and we agree, that

although the State may adopt less stringent criteria than

EPA’s, the State must provide scientifically defensible data

that these criteria will fully protect the waters to which they

apply.
E1HWF7-07-0023-8100080

13

Missouri’s Water Quality Standards and Monitoring

CHAPTER 3

MISSOURI'S PROCESS TO TEST AND ASSESS

WATER QUALITY COULD BE IMPROVED

Missouri made a good effort to monitor its water quality,

but could improve its process to test and assess its waters. 

Missouri needed to design its water quality testing to

comprehensively assess the quality of its waters. Federal

regulations require states to test and assess the quality of all

their waters. Missouri did not have a strategy to

comprehensively evaluate all of its waters. Missouri made

water quality assessments without appropriate testing

results. Missouri did not communicate changing priorities

through updated water quality management plans. As a

result, Missouri did not know the quality of all of its waters

and did not have a plan to find out. 

BACKGROUND CFR part 130.4, Water quality monitoring, requires states

to establish appropriate testing to monitor their water

quality. This monitoring information is to be used to

support activities to abate and control pollution, develop

water quality standards, and report water quality

information to the public, EPA, and Congress. EPA issued

EPA Guidelines for Preparation of the 1996 State Water

Quality Assessments (305(b) Reports) to provide guidance

on testing and assessing water quality. The guidelines

established a target of valid and comparable assessments

within and among states. 

EPA Section 106 and 604(b) Grant Guidance, dated

October 17, 1994, recommended that states provide a

multiyear monitoring strategy with their grant applications. 

The monitoring strategy should address how the state will

assess all waters on a periodic basis using a monitoring

design targeted to the conditions of and use classifications

for the waters. The multiyear strategy was to provide the
Missouri’s Water Quality Standards and Monitoring

E1HWF7-07-0023-8100080

14

framework for the regional/state annual work plan

negotiations. The guidance recommended the state address

specific elements, including but not limited to water quality

problems, information gaps, timelines, testing approaches,

coordination with other agencies, and quality assurance. 

States are required to conduct planning based on water

quality problems identified in their water quality assessment

reports. CFR part 130.5, Continuing planning process,

required states to establish a continuing planning process for

managing their water quality program. CFR part 130.6,

Water quality management plans, required states to prepare

water quality management plans that identify and

recommend procedures to control priority point and

nonpoint water quality problems. The state annual work

programs should be based on the water quality management

plans and water quality problems identified in the water

quality assessment reports. 

MISSOURI NEEDED TO

BETTER PLAN ITS

WATER QUALITY

MONITORING

Missouri did not use available tools to plan its water quality

monitoring. Missouri did not prepare a multiyear strategy

to comprehensively evaluate all its waters and did not

submit to Region 7 annual work plans that addressed all

EPA recommended planning elements. Further, Missouri

did not have a quality assurance management plan that

ensured the data gathered was of sufficient quality. 

Missouri made a good effort to stretch limited resources by

coordinating with other agencies that conducted water

quality testing. However, because Missouri did not use

available planning tools, Missouri did not have sufficient

monitoring data to adequately identify the scope and source

of pollution in its waters.

Missouri did not prepare a multiyear strategy to

comprehensively evaluate all its waters. Missouri drafted a

monitoring plan but did not submit it to EPA. The draft

plan did not meet the recommended elements of a multiyear
Missouri’s Water Quality Standards and Monitoring

E1HWF7-07-0023-8100080

15

strategy as it did not address how the State would assess all

its waters. The plan was generally targeted to specific

waters that Missouri historically monitored. The draft

monitoring plan did not target the monitoring to the

conditions of and use classifications for all waters.

Missouri’s fiscal 1994 through 1997 grant work plans did

not address all EPA recommended planning elements. The

work plans described the planned number of sites to be

monitored. However, the work plans did not fully address

known water quality problems, information gaps, timelines,

and testing approaches as recommended by EPA guidance. 

For example, Missouri staff stated they did not have

adequate information from their current testing to support

their efforts to identify nonpoint source pollution and

sediments. Missouri officials said this lack of information

hampered their development of the impaired waterbody list. 

However, Missouri’s 1994 through 1997 work plans did not

include monitoring strategies to obtain this information. 

Further, Missouri's fiscal 1994 through 1997 grant work

plans did not fully address data quality assurance as

recommended by the guidance. The work plans did not

require a current overarching quality management plan, but

did require quality assurance project plans for individual

projects. EPA requires a quality assurance program for all

environmentally-related activities performed for the Agency. 

Missouri and Region 7 recognized that Missouri's quality

management plan was outdated, and Missouri submitted

drafts of its quality management plan to the Region for its

comments. However, without the quality management plan,

Missouri and EPA have less assurance that water quality

decisions made by the State and EPA are supported by high

quality environmental data. 

While Missouri did not include all the elements in its

planning documents, Missouri made a good effort to stretch

its limited monitoring resources. Missouri coordinated with

other state and federal agencies to obtain their water quality
Missouri’s Water Quality Standards and Monitoring

E1HWF7-07-0023-8100080

16

testing results and avoided duplication of effort. Missouri

also contracted with the U.S. Geological Survey to take

advantage of its expertise in water quality testing. Missouri

implemented a program to train and encourage volunteers

to test water quality. Missouri officials said that the

volunteer testing provided a general indication of problems

that helped Missouri target further testing. The volunteer

testing was perceived as a good way to inform and involve

citizens. 

MISSOURI ASSESSED

WATER QUALITY

WITHOUT

APPROPRIATE TESTING

RESULTS

Missouri assessed its water quality without appropriate

water quality testing results. EPA guidance recommends

states assess only those waters with reliable water quality

information. Missouri assessed waters as unimpaired if it

had no information to the contrary, even if it did not have a

basis for evaluation that was consistent with EPA

guidelines, such as applicable testing results. Missouri

officials said that they did not have adequate resources to

test all use classifications for all waters. As a result,

Missouri assessed waters as clean when it did not know the

true condition of the water. 

EPA Guidelines for Preparation of the 1996 State Water

Quality Assessments (305(b) Reports) requires states assess

only those waters with reliable water quality information. 

States are allowed to assess waterbodies based on reliable

indicators of water quality in addition to direct testing. 

Nevertheless, states may not assess waters as unimpaired in

the absence of sufficient information to make the

assessment.

Missouri assessed waters as unimpaired if it had no

information to the contrary. We reviewed assessments for

60 waterbodies and found that Missouri tested some

pollutants for specific uses but inappropriately applied the

test results to all use classifications. For example, Missouri

assessed seven waterbodies as supporting the “swimmable” 
Missouri’s Water Quality Standards and Monitoring

E1HWF7-07-0023-8100080

17

use classification but did not test for bacteria limited by its

criteria. Missouri assessed one river as supporting the

swimmable use classification, without determining whether

the bacteria levels met its criteria. Further, Kansas listed the

upstream portion of the river as impaired due to the level of

the bacteria present in the water at that point. 

MISSOURI DID NOT

UPDATE WATER

QUALITY

MANAGEMENT PLANS

Missouri did not communicate changing water quality

priorities through updated water quality management plans. 

Federal regulations require the states to prepare a

continuing planning process and water quality management

plans and update the plans as needed. The water quality

management plans, along with current water quality

problems, are the basis for state annual work plans. 

Missouri documented its continuing planning process in

1977 and its water quality management plan in 1979 but had

not updated them. Missouri should have revisited its

planning documents to ensure that they continued to focus

on priority areas. EPA and other states have been sued for

inadequate or outdated water quality plans, and a proactive

planning approach would help avoid having the courts set

Missouri’s water quality priorities. 

CONCLUSION Missouri could not fully answer the public’s question: Is my

water safe to swim in, fish from, or drink? Missouri

believes that its water quality is improving, but has not

targeted its monitoring to fully identify the picture of its

water quality. Without up-to-date management plans,

neither Missouri nor Region 7 could ensure the highest

priority water quality problems were addressed. Because

the State was not identifying its plans in writing, it did not

ensure that it identified problems, planned actions,

established milestones, and tracked progress after taking

action. 
Missouri’s Water Quality Standards and Monitoring

E1HWF7-07-0023-8100080

18

RECOMMENDATIONS We recommend that the Regional Administrator:

3.1 Provide technical assistance to help Missouri

develop a multiyear monitoring strategy and

monitoring work plan to address the elements

described in the grant guidance and submit these

documents with its grant application. 

3.2 Request that Missouri's monitoring work plan

address how Missouri will target water quality

testing for use classifications, water quality

problems, and information gaps.

3.3 Request that Missouri address quality assurance

as an element of the grant monitoring work plan. 

Continue to assist Missouri to develop a quality

management plan.

3.4 Request that Missouri report assessments of

waterbodies consistent with EPA water quality

assessment report guidelines.

3.5 Require that Missouri review and update its

continuing planning process and water quality

management plan to reflect changing conditions

and current water quality priorities. 

AUDITEE COMMENTS

AND OIG EVALUATION

Region 7 generally agreed with the findings and

recommendations. The Region provided comments to

clarify portions of the report, and we have incorporated

these comments and modified the report as appropriate. 
E1HWF7-07-0023-8100080

19

Missouri’s Water Quality Standards and Monitoring

CHAPTER 4

MISSOURI SHOULD HAVE PROCEDURES FOR COMPLETE 

AND ACCURATE WATER QUALITY REPORTING

Missouri’s reporting procedures did not ensure its water

quality reports were complete and accurate. Federal

regulations require states to report on the quality of all

waters of the state. Missouri excluded assessments it made

of intermittent streams from its 1996 water quality

assessment reports. Missouri did not retain a list of specific

waters the State included in summary tables in the report;

thus, the report was not verifiable. Further, Missouri did

not ensure that data systems used to generate the reports

contained accurate information. As a result, Missouri did

not comprehensively report on its water quality. EPA uses

information from state water quality assessment reports to

measure state performance in protecting and maintaining

water quality. 

BACKGROUND The Clean Water Act section 305(b) requires states to

prepare and submit to EPA a report describing the water

quality of all waters of the United States within the state

every 2 years. CFR part 130.8, Water quality report, states

that the water quality assessment reports serve as the

primary assessment of state water quality and provide the

basis for water quality management planning. CFR part

122.2, Definitions, defines waters of the United States to

include intermittent streams and tributaries of waters that

could affect interstate commerce. Intermittent streams are

streams that are not continuous or do not flow all year. 

EPA Guidelines for Preparation of the 1996 State Water

Quality Assessments (305(b) Reports) recommends that

states report on all waters for which reliable water quality

information is obtained. 

Clean Water Act section 303(d) requires the states to list
Missouri’s Water Quality Standards and Monitoring

E1HWF7-07-0023-8100080

20

impaired waterbodies. The impaired waterbody list is used

to schedule waterbodies for the development of total

maximum daily loads, which are calculations to limit or

control pollutant discharges to restore the water quality. 

CFR part 130.7, Total maximum daily loads (TMDL) and

individual water quality-based effluent limitations, requires

states to identify all impaired waterbodies where existing

pollution control requirements are not stringent enough to

achieve the water quality standards. To develop the list,

each state is required to use all existing and readily available

water quality related data, including the water quality

assessment report. Each state is required to provide to EPA

documentation to support its decision to list or not list its

waters. EPA's Guidance for 1994 303(d) Lists (also

applicable for 1996) said that the state should plan to collect

additional information if testing results are not sufficient to

determine if a waterbody should be included on the impaired

waterbody list. 

EPA Guidelines for Preparation of the 1996 State Water

Quality Assessments (305(b) Reports) recommends that

states keep their monitoring and assessment databases

current to simplify report preparation and increase the

usefulness of assessment data. EPA Section 106 and 604(b)

Grant Guidance recommends that the grant work plans

provide for data storage, management, and sharing. The

guidance recommends that states store quality assured data

in a computerized database.

MISSOURI EXCLUDED

ASSESSMENTS OF

INTERMITTENT

STREAMS FROM ITS

WATER QUALITY

ASSESSMENT 

REPORT

Missouri did not report the assessments it had made of its

smaller, intermittent streams. Although Missouri staff

tested and assessed many intermittent streams, they believed

that reporting on these intermittent streams was not

required. Federal regulations require states to report on all

waters, including intermittent streams and tributaries of

waters, that could affect interstate commerce. Missouri

staff estimated 60 percent of Missouri's permit holders
Missouri’s Water Quality Standards and Monitoring

E1HWF7-07-0023-8100080

21

discharged into intermittent streams, which thus could affect

interstate commerce. Also, the intermittent streams often

are tributaries of significant streams that Missouri includes

in its water quality assessment report. As a result,

Missouri’s water quality reports were not complete, and

Missouri was not ensuring it identified and developed

measures to control water quality problems for these

streams. 

MISSOURI COULD NOT

IDENTIFY SPECIFIC

WATERS INCLUDED

IN ITS WATER 

QUALITY REPORT

Missouri’s 1996 water quality assessment report was not

verifiable. Missouri appropriately included summary totals

in this report. However, it did not retain a list of the

waterbodies that made up the summary totals, either in hard

copy or computerized form, and could not reconstruct the

report. Further, Missouri staff said they did not review the

summary totals in the report for accuracy as they did not

have the resources to conduct this review. As a result,

Missouri’s water quality reports were not supportable. 

Missouri agreed to maintain copies of the detailed support

and review the report for accuracy in the future. 

MISSOURI COULD NOT

JUSTIFY EXCLUSION OF

IMPAIRED

WATERBODIES FROM

THE IMPAIRED

WATERBODY LIST 

Missouri did not document the impaired waters that were

excluded from the 1996 impaired waterbody list. CFR part

130.7 requires each state to use all existing and readily

available information to develop the impaired waterbody

list, including the most recent water quality assessment

report. Although the regulation allows a state to exclude an

impaired water from the list, the state must demonstrate

good cause for excluding the water. Recent court rulings

have evaluated the sufficiency of the impaired waterbody list

based on the impaired waterbodies identified in the water

quality assessment report. 

Missouri staff did not retain a list of all impaired

waterbodies reported in its water quality assessment report,
Missouri’s Water Quality Standards and Monitoring

E1HWF7-07-0023-8100080

22

along with justification for exclusion from the list. 

Therefore, we could not assess the completeness of the

impaired waterbody list, nor could Missouri be assured that

waters were not inadvertently or inappropriately omitted

from the list. 

Missouri representatives told us that they excluded some

waterbodies from the impaired waterbody list because they

had inadequate test results. We reviewed a sample of 60

waterbodies, of which 29 were impaired. Missouri

representatives stated they excluded 23 of the 29 impaired

waterbodies based on inadequate test results. However,

Missouri did not update its monitoring plan to schedule the

23 waterbodies for additional testing for the pollutant

causing the impairment, although Missouri staff said they

intended to begin monitoring these waterbodies beginning in

about 2002. 

MISSOURI DID NOT

HAVE PROCEDURES

TO ENSURE DATA

SYSTEMS WERE

COMPLETE AND

ACCURATE

Missouri did not ensure that data systems used to track

monitoring results accurately reflected use classifications

and water quality assessments. Prudent business practices

would require that data entry procedures ensure the data

was entered timely and routinely verified. Missouri did not

have procedures to verify the data in its water quality data

systems and did not update the data timely. Additionally,

Missouri did not record its water quality testing results in

EPA’s water quality database. As a result, the data systems

Missouri and EPA used to track water quality testing and

assessments were not accurate or complete.

Missouri did not verify the accuracy and completeness of

data entered into its Water Quality Information System. 

Missouri uses the Water Quality Information System to

track testing and assessment results and generate the water

quality assessment report. Missouri staff said they did not

have procedures to ensure that the data was accurate. We

reviewed a sample of 60 waterbodies and found 7
Missouri’s Water Quality Standards and Monitoring

E1HWF7-07-0023-8100080

23

waterbodies with inaccurate use classifications and 3 with

an inaccurate water quality test date. Further, we found

two waterbodies that were not included in the Water

Quality Information System. Missouri agreed to assign a

person to review the accuracy of the information in the

system on a routine basis. 

Missouri did not update the Water Quality Information

System timely. Missouri did not enter the 1994 use

classification changes until the fall of 1997. Accurate use

classification information is essential for water quality

assessments, which Missouri makes routinely during the

year. 

Missouri did not record its water quality testing results in

STORET (STOrage and RETrieval), the EPA database

used to record water quality test results. States, federal

agencies, local governments, and universities use STORET. 

Missouri officials said STORET was cumbersome to use;

however, Missouri staff used STORET test information

from bordering states and other agencies to assess

Missouri's waters. However, the bulk of Missouri's water

quality testing was conducted by other agencies, such as the

U.S. Geological Survey, that did update STORET. EPA

Section 106 and 604(b) Grant Guidance recommends that

the monitoring work plans provide for water quality test

data to be entered into STORET within 3 to 6 months. 

However, EPA did not require Missouri to update STORET

as a grant condition. As a result, STORET did not contain

complete information on Missouri's water quality.

CONCLUSION Missouri needs to make sure that its water quality reports

contain as accurate information as possible, or risk

contributing to inadequate or inappropriate decisions or

activities to control water pollution. Without accurate

reports, Missouri may not take timely action to identify

impaired waters and establish maximum pollutant loads into
Missouri’s Water Quality Standards and Monitoring

E1HWF7-07-0023-8100080

24

these waters. EPA and Congress rely on information from

state water quality reports to identify where the nation

needs to focus pollution control resources. As an example,

the current emphasis on nonpoint source pollution control

came from information in state water quality reports that

nonpoint source pollution had become more of a problem

than point source pollution. 

RECOMMENDATIONS We recommend that the Regional Administrator:

4.1 Request that Missouri provide complete and

accurate reports as an element of its monitoring

work plan. Request Missouri include water

assessments consistent with EPA water quality

assessment report guidelines. 

4.2 Work with Missouri to implement internal

control procedures to ensure that water quality

reports are complete and accurate, and retain

documentation to support the reports. 

4.3 Require Missouri to document the impaired

waters excluded from the impaired waterbody

list and provide adequate justification. Request

Missouri to plan testing to address information

gaps where insufficient information exists to

conclude if a waterbody should be included on

its impaired waterbody list. 

4.4 Request that Missouri provide for data storage,

management, and sharing as an element of its

monitoring work plan. 

4.5 Work with Missouri to implement internal

controls to ensure that its information systems

are complete and accurate. Provide technical

assistance to prompt Missouri to enter

information into STORET. 
Missouri’s Water Quality Standards and Monitoring

E1HWF7-07-0023-8100080

25

AUDITEE COMMENTS

AND OIG EVALUATION

Region 7 generally agreed with the findings and

recommendations. The Region provided comments to

clarify portions of the report, and we have incorporated

these comments and modified the report as appropriate.
E1HWF7-07-0023-8100080

26

Missouri’s Water Quality Standards and Monitoring

CHAPTER 5

REGION 7 SHOULD IMPROVE OVERSIGHT AND TECHNICAL

ASSISTANCE FOR MISSOURI'S WATER QUALITY PROGRAMS

Region 7 could have provided better technical assistance

and oversight to ensure that Missouri had an adequate basis

for its water quality programs. Region 7 did not fulfill its

responsibility to approve Missouri's water quality standards;

however, the Region recognized its responsibility and

committed to timely approval actions in its fiscal 1998/1999

regional management agreement. The Region did not

require as a grant condition that Missouri use available

water quality management tools. Also, the Region

approved Missouri's impaired waterbody list without

confirming the list was complete. As a result, the Region

could not be sure Missouri protected its water quality as

envisioned by the Clean Water Act. 

BACKGROUND The Clean Water Act requires EPA to review water quality

standards adopted by a state and approve the standards if

they are consistent with the Act. If any standards are not

consistent with the Act, EPA must notify the state within 90

days of receipt of the state adopted standards and specify

required changes. If the state does not adopt the changes

within 90 days of the notification, EPA is required to

promptly take action to promulgate the requested changes. 

EPA's Section 106 and 604(b) Grant Guidance was

intended to be a tool for the regions to work with the states

to improve water quality testing and assessing. The

guidance recommends that each state develop a monitoring

strategy for gathering water quality information to support

state activities to develop water quality standards, measure

progress in improving water quality, and develop the

impaired waterbody list. 
Missouri’s Water Quality Standards and Monitoring

E1HWF7-07-0023-8100080

27

The Clean Water Act requires that EPA review and approve

or disapprove a state's impaired waterbody list. If EPA

disapproves the list, EPA is responsible for identifying the

waters that should be included in the list. CFR part 130.7,

Total maximum daily loads (TMDL) and individual water

quality-based effluent limitations, requires each state to

provide to EPA documentation to support its decision to list

or not list its waters. 

REGION 7 DID NOT

APPROVE MISSOURI'S

WATER QUALITY

STANDARDS

Region 7 did not timely approve Missouri's water quality

standards. Region 7 did not approve Missouri’s 1994 water

quality standards dated March 30, 1994, nor the 1996 water

quality standards dated October 31, 1996. Region 7

personnel said several factors contributed to their not

approving Missouri’s water quality standards, including

uncertainty over applicable EPA criteria and inadequate

resources to review state water quality standards. Region 7

recognized its need to approve state standards as a fiscal

1997 Federal Managers’ Financial Integrity Act area of

concern, and committed in its fiscal 1998/1999 regional

management agreement to complete timely approval

actions. 

Region 7 reviewed but neither approved nor disapproved

Missouri 1994 water quality standards, and had not

reviewed Missouri’s 1996 standards. Region 7 provided

Missouri substantive deficiency comments in a letter dated

November 29, 1993, for the draft 1994 standards. Missouri

made some changes to its standards, but did not address all

of the Region's comments. For example, Missouri adopted

“fishable” criteria for mercury at 0.5 micrograms per liter,

but EPA recommended criteria of 0.012 micrograms per

liter. Missouri said that quantities of mercury were higher

in its water from natural sources so it was not practical to

adopt EPA criteria. However, Region 7 said that Missouri

would need to adopt the EPA criteria universally, and

establish site-specific criteria for individual waters with
Missouri’s Water Quality Standards and Monitoring

E1HWF7-07-0023-8100080

28

naturally higher levels. Missouri did not implement the

Region's recommendations, and Region 7 did not

disapprove Missouri’s criteria that were less protective than

EPA criteria. As a result, Missouri is not adequately

protecting its water uses. 

The Region did not require Missouri to provide the required

studies to support uses that did not meet the “swimmable”

use classification. CFR 131.20, State Review and revision

of water quality standards, requires that states submit these

studies to the Region for review and approval along with its

revised water quality standards. In 1993, Region 7

informed Missouri that these studies were needed. 

However, Missouri did not conduct the studies. Again,

Region 7 did not disapprove Missouri’s 1994 and 1996

water use classifications that were not supported by the

required studies. As a result, Missouri did not protect the

waterbodies for bacteria that can be harmful to human

health.

In 1993, Region 7 told Missouri that it should not remove

use classifications for “existing uses.” In its 1996 standards,

Missouri removed drinking water supply use classifications

for 15 lakes, of a total of 455 lakes, that may have been

“existing.” Federal regulations do not permit the removal of

a water use classification if it was “existing” or actually

achieved on or after November 28, 1975. States have

raised an issue with EPA that common sense would support

allowing the removal of the use classification for a

waterbody that likely will never again be used for drinking

water supply. Region 7, in consultation with Office of

Water, should have determined whether to allow Missouri

to remove the uses or promulgate standards for Missouri for

these waterbodies. 

Region 7 personnel said they were uncertain about

applicable criteria because Office of Water did not maintain

a comprehensive list of the latest EPA-published criteria. 

New scientific knowledge about the effect of pollutants on
Missouri’s Water Quality Standards and Monitoring

E1HWF7-07-0023-8100080

29

water quality contributed to the confusion over which

criteria should be applied. This confusion was not unique to

Region 7 as Region 8 developed a guide for its states to use

that listed EPA-published criteria. 

In addition, Regional officials said they had inadequate

resources to timely approve state water quality standards. 

Also, the water quality standards coordinator was assigned

additional duties which interfered with the timely review of

state standards. Region 7 assigned one person to review the

standards for all four states until January 1997, when the

Region assigned a second person. However, Regional

officials still did not believe the resources were adequate. 

We surveyed Regions 3, 5, 6, and 8 and found all were

current in their reviews. Region 3 assigned one position to

review all state water quality standards with assistance from

the project officers for each state. Regions 5, 6, and 8

assigned between 0.3 and 1.0 positions per state. 

REGION 7 DID NOT

REQUIRE MISSOURI

TO USE WATER

QUALITY

MANAGEMENT TOOLS 

The Region did not require as a grant condition that

Missouri use available water quality management tools to

plan its water quality monitoring. The Region did not

ensure that Missouri's planning process addressed all

elements of EPA's grant guidance. However, Region 7 is

working with Missouri to update its data quality

management plan. As a result, Region 7 provided funding

for Missouri’s monitoring program without ensuring

Missouri planned to obtain all the water quality information

it needed to support its water quality programs. 

The Region did not ensure that Missouri's planning process

addressed all elements of EPA's Section 106 and 604(b)

Grant Guidance. The Region did not require that Missouri

submit a monitoring strategy or work plans with its grant

applications. However, in its fiscal 1998/1999 regional

management agreement, the Region recognized the

importance of the monitoring strategies, and requested
Missouri’s Water Quality Standards and Monitoring

E1HWF7-07-0023-8100080

30

Office of Water reissue and reinforce its water quality

monitoring strategy guidance; i.e., EPA's Section 106 and

604(b) Grant Guidance. 

Region 7 recognized the need for states to develop and

update comprehensive water quality management planning

processes, and identified this need as a Federal Managers’

Financial Integrity Act area of concern for fiscal 1997. The

Region hired a water quality specialist to work with the

states to develop and update their planning processes. 

In its fiscal 1998/1999 regional management agreement,

Region 7 stated it had limited success with states adopting

national core performance measures. For example, for fiscal

1998, Missouri agreed to provide water quality assessment

information that relates to core measures, such as

“percentage of assessed waterbodies that support use

designations,” but did not establish specific targets. 

Missouri did not commit to Office of Water's core state

reporting requirements for fiscal 1998, such as describing

how its statewide monitoring program conforms with EPA's

Section 106 and 604(b) Grant Guidance to achieve a

comprehensive assessment of water quality. The Region

said it planned to continue to persuade states to adopt

national core measures in fiscal 1999 work plan agreements. 

Region 7 staff have begun identifying elements of Missouri's

strategic planning documents that tie to the national core

measures. 

Region 7 had not required as a condition of funding that

Missouri have a current data quality management plan. 

Missouri and Region 7 recognized that Missouri's quality

management plan was outdated, and the Region had been

working with Missouri since January 1996 to update its

quality management plan. However, the Region did not

require Missouri to commit to developing the plan in its

monitoring work plan as recommended by EPA's Section

106 and 604(b) Grant Guidance.
Missouri’s Water Quality Standards and Monitoring

E1HWF7-07-0023-8100080

31

REGION 7 APPROVED

MISSOURI’S IMPAIRED

WATERBODY LIST

WITHOUT ENSURING

IT WAS COMPLETE

Region 7 approved Missouri's 1996 impaired waterbody list

without ensuring the list was complete. Region 7 should

have determined which impaired waterbodies were included

in the water quality assessment report but excluded from the

impaired waterbody list in order to meet its responsibility to

ensure the list was complete and fully approvable. Without

adequate procedures to confirm that the 303(d) list is

complete, Missouri and EPA may be vulnerable to having

the courts set their priorities for them in response to

lawsuits. EPA and other states have been sued for

inadequate 303(d) lists. Additionally, Missouri may not

take timely action to identify impaired waters and establish

maximum pollutant loads into these waters. Region 7 said,

for future impaired waterbody lists, the Region will require

and review supporting information, including a list of

waterbodies that make up the summary totals Missouri

reports in the water quality assessment report. 

CONCLUSION Region 7 could have provided better technical assistance

and oversight to ensure that Missouri had an adequate basis

for its water quality programs. Region 7 delayed taking

action on Missouri's water quality standards, and did not

fulfill its responsibility to ensure Missouri's use

classifications and criteria protect water quality at the

national level. Region 7 should ensure that Missouri sets

standards that are scientifically defensible and that protect

the people and wildlife that use the water. 

By not requiring that Missouri include the recommended

elements in its monitoring work plans, Region 7 sent the

message that continued funding was not dependent on an

effective water quality monitoring program. Region 7

should better tie funding to performance by requiring that

Missouri include the recommended elements in its grant

work plans. 
Missouri’s Water Quality Standards and Monitoring

E1HWF7-07-0023-8100080

32

RECOMMENDATIONS We recommend that the Regional Administrator:

5.1 Evaluate the functions currently performed by

the water quality standards coordinators. 

Determine how many employees are needed to

accomplish the functions, and the most efficient

and effective assignment of these functions. 

5.2 Prioritize the timely review of and prompt action

on state water quality standards. 

5.3 Use the elements of the grant monitoring work

plan as a basis for a review of Missouri's water

quality testing and assessing program. Identify

where the Region can best provide technical

assistance to ensure that Missouri's assessments

will achieve EPA's target of comprehensive and

consistent water quality assessments. 

5.4 Require and review supporting information for

Missouri's impaired waterbody list, including a

reconciliation to the water quality assessment

report. 

AUDITEE COMMENTS

AND OIG EVALUATION

Region 7 generally agreed with the findings and

recommendations. The Region provided comments to

clarify portions of the report, and we have incorporated

these comments and modified the report as appropriate. 
E1HWF7-07-0023-8100080

33

Missouri’s Water Quality Standards and Monitoring

EXHIBIT 1

SCOPE AND METHODOLOGY

We reviewed Missouri's internal controls over water quality standards setting, monitoring, and

reporting. We analyzed internal controls to assure compliance with federal statutory and

regulatory criteria and with the State's policies and procedures. We determined whether Region

7's Federal Managers’ Financial Integrity Act reports disclosed any material weaknesses

applicable to the audit. Our audit disclosed several areas needing improvements that are

discussed in Chapters 2 - 5.

To determine Missouri’s process for establishing water quality standards, we interviewed

Missouri’s Water Pollution Control Program staff and flowcharted their internal processes for

developing use classifications and establishing water criteria. We reviewed Missouri’s water

quality standards as adopted in its Rules of Department of Natural Resources, Division 20 -

Clean Water Commission, Chapter 7 - Water Quality, and reviewed policy and guidance papers

to determine if the process for establishing water quality standards was in compliance with the

Clean Water Act and applicable federal regulations. 

To review Missouri’s water monitoring program, we interviewed staff members of the Planning

Section, Water Pollution Control Program and flowcharted their process for testing and assessing

water quality. We also flowcharted the process for water quality assessment reporting and

impaired waters listing. We observed a staff member of the Water Pollution Control Program

while he conducted inspections of wastewater treatment facilities and their receiving streams. 

During these site visits, we observed the work performed and discussed the process for

monitoring water with the staff member. We reviewed EPA guidance for designing monitoring

programs and guidance for reporting to EPA the results of testing and assessing states’ waters. 

We selected a sample of 60 waterbodies to evaluate the process of setting use classifications,

establishing water criteria, testing and assessing the waterbodies, recording results in the State's

Water Quality Information System database, and reporting test results. We selected the sample

from the list of waterbodies and use classifications in Missouri's 1996 water quality standards. 

We judgmentally selected the waterbodies to obtain a mixture of geographic location, size, and

water quality. We selected waters assessed as both impaired and unimpaired. 

We selected a sample of 30 National Pollution Discharge Elimination System permits issued by

Missouri to determine if any permittees discharged pollutants for which Missouri did not have

water quality criteria. We judgmentally selected these permits to include both large and small

dischargers, and dischargers in a variety of industries. 
E1HWF7-07-0023-8100080

34

To determine if Region 7 implemented effective procedures to approve state implementation plans

and water quality standards, and to evaluate Missouri's water quality standards setting, testing,

assessing and reporting, we interviewed Region officials to determine how they ensured

compliance with the Clean Water Act. We determined their process for reviewing states’ water

quality standards, water quality assessment report, and impaired waterbody list. We also

reviewed correspondence between the Region and Missouri. We reviewed the accuracy and

reliability of the state water quality information that EPA and Missouri use as a basis for

measuring performance in water pollution prevention and control. 
E1HWF7-07-0023-8100080

35

Missouri’s Water Quality Standards and Monitoring

EXHIBIT 2

LESS RESTRICTIVE CRITERIA IN MISSOURI’S 1996 WATER QUALITY STANDARDS

Pollutant “Priority”

Toxic

Description Missouri Explanation

1. 1,3 Dichloropropylene Yes No criteria for drinking water supply or

fish consumption

No explanation, agreed to

include in next standards

revision

2. Selenium Yes No short term criteria for “fishable” No explanation, agreed to

include in next standards

revision

3. Pentachlorophenol Yes No short term criteria for “fishable” No explanation, agreed to

include in next standards

revision

4. Chlorpyrifos No No short term criteria for “fishable” No explanation, agreed to

include in next standards

revision

5. Arsenic Yes No criteria for fish consumption or

short term criteria for “fishable”

Natural condition prevented

adopting the EPA criteria

6. Mercury Yes No criteria for fish consumption; less

restrictive long term criteria for

“fishable”

Natural condition prevented

adopting the EPA criteria

7. Aluminum No No long term criteria for “fishable” Natural condition prevented

adopting the EPA criteria

8. Fecal coliform No No criteria for recreation such as

boating, wading, and fishing

Too expensive to implement

9. Dichlorodifluoromethane No No criteria for drinking water supply Missouri was unaware of

EPA criteria

10. N-nitros-pyrroliden No No criteria for drinking water supply Missouri was unaware of

EPA criteria

11. Parathion No No short term and less restrictive long

term criteria for “fishable”

Criteria taken from outdated

EPA guidance

12. 4, 4', DDT Yes No short or long term criteria for

“fishable,” less restrictive criteria for

drinking water supply and fish

consumption

No explanation

13. 4,4' DDE Yes Less restrictive criteria for drinking

water supply and fish consumption

No explanation

14. 4,4' DDD Yes Less restrictive criteria for drinking

water supply and fish consumption

No explanation
Missouri’s Water Quality Standards and Monitoring

E1HWF7-07-0023-8100080

36

EXHIBIT 3

POLLUTANTS LIMITED IN PERMITS BUT

NOT IN WATER QUALITY STANDARDS

1. Bromide

2. Ethylene glycol dinitrate

3. Molybdenum

4. Nitroglycerine

5. Phosphorus

6. Tin

7. Titanium

8. Total organic halogens

9. Vandium
E1HWF7-07-0023-8100080

37

Missouri’s Water Quality Standards and Monitoring

APPENDIX I

EPA COMMENTS
E1HWF7-07-0023-8100080

42

Missouri’s Water Quality Standards and Monitoring

APPENDIX II

DISTRIBUTION

Office of Inspector General

Inspector General (2410)

Deputy Assistant Inspector General for Internal Audits (2421)

Headquarters Audit Liaison (2421)

Divisional Inspectors General for Audit

EPA Headquarters Office

Assistant Administrator for Water (4101)

Agency Followup Official (2710)

Agency Followup Coordinator (3304)

Associate Administrator for Congressional and Legislative Affairs (1301)

Associate Administrator for Communications, Education, and Public Affairs (1701)

Associate Administrator for Regional Operations and State/Local Relations (1501)

Headquarters Library (3401)

EPA Region 7

Director, Water, Wetlands, and Pesticides Division

Director, Office of External Programs

Audit Followup Coordinator

Regional Offices

Regional Administrators

Missouri Department of Natural Resources

Director

Director of Staff, Water Pollution Control Program

Planning Section Chief, Water Pollution Control Program