APPENDIX A

BACKGROUND ON THE CLEAN WATER ACT AND 

EFFLUENT GUIDELINES PROGRAM
Appendix A−Background On The Clean Water Act And Effluent Guidelines Program

APPENDIX A BACKGROUND ON THE CLEAN WATER ACT AND EFFLUENT 

GUIDELINES PROGRAM

This appendix provides information on the Clean Water Act (CWA) and an explanation 

of different levels of controls for effluent limitations guidelines and standards (ELGs). 

A.1 Effluent Limitation Guidelines and Pretreatment Standards Overview

The national clean water industrial regulatory program is authorized under Sections 301, 

304, 306, and 307 of the CWA. 

The CWA directs EPA to promulgate categorical regulations through six levels of 

control: 

1. Best practicable control technology currently available (BPT)

2. Best available control technology economically achievable (BAT) 

3. Best conventional control technology (BCT) 

4. New source performance standards (NSPS)

5. Pretreatment standards for existing sources (PSES)

6. Pretreatment standards for new sources (PSNS)

For point sources that discharge pollutants directly into the waters of the United States (direct 

dischargers), the limitations and standards promulgated by EPA are implemented through 

National Pollutant Discharge Elimination System (NPDES) permits. See CWA Sections 301(a), 

301(b), and 402. For sources that discharge to POTWs (indirect dischargers), EPA promulgates 

pretreatment standards that apply directly to those sources and are enforced by POTWs and state 

and federal authorities. See CWA Sections 307(b) and (c). Figure A-1 illustrates the relationship 

between the regulation of direct and indirect dischargers. 

A-1 
Appendix A−Background On The Clean Water Act And Effluent Guidelines Program

Figure A-1. Regulations of Direct and Indirect Wastewater Discharges 

A.2 BPT — CWA Sections 301(b)(1)(A) and 304(b)(1) 

EPA develops effluent limitations based on BPT for conventional, toxic, and 

nonconventional pollutants. CWA Section 304(a)(4) designates the following as conventional 

pollutants: biochemical oxygen demand (BOD5), total suspended solids, fecal coliform, pH, and 

any additional pollutants defined by the Administrator as conventional. The Administrator 

designated oil and grease as an additional conventional pollutant on July 30, 1979 (see 44 FR 

44501). EPA has identified 65 pollutants and classes of pollutants as toxic pollutants, of which 

126 specific substances have been designated priority toxic pollutants. See Appendix A to Part 

423, reprinted after 40 CFR Part 423.17. All other pollutants are considered to be 

nonconventional. 

In specifying BPT, EPA looks at a number of factors. EPA first considers the total cost of 

applying the control technology in relation to the effluent reduction benefits. The Agency also 

considers the age of the equipment and facilities, the processes employed and any required 

process changes, engineering aspects of the control technologies, non-water-quality 

environmental impacts (including energy requirements), and such other factors the EPA 

Administrator deems appropriate. See CWA Section 304(b)(1)(B). Traditionally, EPA 

establishes BPT effluent limitations based on the average of the best performances of facilities 

within the industry of various ages, sizes, processes, or other common characteristics. Where 

existing performance is uniformly inadequate, BPT may reflect higher levels of control than 

currently in place in an industrial category if the Agency determines that the technology can be 

applied practically. 

NSPS

• Conventional Pollutants

• Nonconventional Pollutants

• Priority Pollutants (Toxics)

BPT

• Conventional Pollutants

• Nonconventional Pollutants

• Priority Pollutants (Toxics)

BCT

• Conventional Pollutants

BAT

• Nonconventional Pollutants

• Priority Pollutants (Toxics)

New 

Sources

Existing 

Sources

Direct Dischargers

PSNS

• Nonconventional Pollutants

• Priority Pollutants (Toxics)

PSES

• Nonconventional Pollutants

• Priority Pollutants (Toxics)

Indirect Dischargers

A-2 
Appendix A−Background On The Clean Water Act And Effluent Guidelines Program

A.3 BCT — CWA Sections 301(b)(2)(E) and 304(b)(4)

The 1977 amendments to the CWA required EPA to identify effluent reduction levels for 

conventional pollutants associated with BCT for discharges from existing industrial point 

sources. In addition to the other factors specified in Section 304(b)(4)(B), the CWA requires that 

EPA establish BCT limitations after consideration of a two-part “cost-reasonableness” test. EPA 

explained its methodology for the development of BCT limitations in 1986 (see 51 FR 24974, 

July 9, 1986).

A.4 BAT — CWA Sections 301(b)(2)(A) and 304(b)(2) 

For toxic pollutants and nonconventional pollutants, EPA promulgates effluent guidelines 

based on BAT. See CWA Sections 301(b)(2)(A), (C), (D), and (F). The factors considered in 

assessing BAT include the cost of achieving BAT effluent reductions, the age of equipment and 

facilities involved, the process employed, potential process changes, non-water-quality 

environmental impacts (including energy requirements), and such other factors the EPA 

Administrator deems appropriate. See CWA Section 304(b)(2)(B). The technology must also be 

economically achievable; see CWA Section 301(b)(2)(A). In addition to end-of-pipe wastewater 

treatment, BAT limitations may be based on effluent reductions attainable through changes in a 

facility’s processes and operations. Where existing performance is uniformly inadequate, BAT 

may reflect a higher level of performance than is currently being achieved within a particular 

subcategory based on technology transferred from a different subcategory or category. BAT may 

be based upon process changes or internal controls, even when these technologies are not 

common industry practice. 

A.5 NSPS — CWA Section 306 

NSPS reflect effluent reductions that are achievable based on the best available 

demonstrated control technology. New sources have the opportunity to install the best and most 

efficient production processes and wastewater treatment technologies. As a result, NSPS should 

represent the most stringent controls attainable through the application of the best available 

demonstrated control technology for all pollutants (i.e., conventional, nonconventional, and 

priority pollutants). In establishing NSPS, EPA takes into consideration the cost of achieving the 

effluent reduction and any non-water-quality environmental impacts and energy requirements. 

See CWA section 306(b)(1)(B).

A.6 PSES — CWA Section 307(b) 

PSES apply to indirect dischargers and are designed to prevent the discharge of pollutants 

that pass through, interfere with, or are otherwise incompatible with the operation of POTWs, 

including wastewater conveyance and sludge disposal. Pretreatment standards are technologybased and are analogous to BAT effluent limitations guidelines. See CWA section 301(b)(1)(A).

The General Pretreatment Regulations, which set forth the framework for implementing 

national pretreatment standards, are found at 40 CFR Part 403. 

A-3 
Appendix A−Background On The Clean Water Act And Effluent Guidelines Program

A.7 PSNS — CWA Section 307(c) 

Like PSES, PSNS apply to indirect dischargers and are designed to prevent the 

discharges of pollutants that pass through, interfere with, or are otherwise incompatible with the 

operation of POTWs. PSNS are to be issued at the same time as NSPS. See CWA Section 

307(c). New indirect dischargers have the opportunity to incorporate into their plants the best 

available demonstrated technologies. The Agency considers the same factors in promulgating 

PSNS as it considers in promulgating NSPS. 

A-4 
APPENDIX B

QUALITY ASSURANCE ACTIVITIES SUPPORTING 

THE 2012 ANNUAL REVIEW REPORT
Appendix B–Quality Assurance Activities Supporting The 2012 Annual Review Report

APPENDIX B QUALITY ASSURANCE ACTIVITIES SUPPORTING THE 2012 

ANNUAL REVIEW REPORT

B.1 Background, Data Needs, and Data Sources

This appendix provides documentation on the data usability and quality of the new data 

sources for the 2012 Annual Review. 

B.2 Background 

For the 2012 Annual Review, EPA explored additional data sources and conducted six 

new analyses to supplement the toxicity rankings analysis (TRA) conducted as part of the 2011 

Annual Review. The six analyses EPA explored during the 2012 Annual Review included: 

• Identification of Industrial Wastewater Pollutants in Sewage Sludge 

• Review of Chemical Action Plans

• Identification of Wastewater Discharges Related to Air Pollution Control Not 

Currently Covered by ELGs 

• Review of Toxic Release Inventory (TRI) Industry Sectors Expansion 

• Review of Analytical Methods 

• Review of Industrial Wastewater Treatment Technologies 

EPA’s goals in conducting these specific analyses were to identify new wastewater 

discharges or pollutants not previously regulated and to identify wastewater discharges that can 

be eliminated or treated more effectively. During the 2012 Annual Review, EPA continued 

preliminary category reviews for three point source categories (40 CFR Parts 419 – Petroleum 

Refining, 430 – Pulp, Paper, and Paperboard, and 432 – Meat and Poultry Products) identified 

during EPA’s 2011 Annual Review (U.S. EPA, 2012). Additionally, EPA reviewed public 

comments and input from stakeholders as part of the 2012 Annual Review. For more information 

on the methodology for EPA’s 2012 Annual Review, see Part II (EPA’s 2012 Annual Review 

Methodology and Analyses) of this report. 

EPA documented the usability and quality of the data from each source used to support 

the six new analyses. Quality assurance, at the project level, is the system of procedures used to 

assess and evaluate project data, information, or analysis outputs against data quality objectives 

and acceptance criteria. This appendix evaluates quality assurance for the data collected, 

evaluated, and cited in this 2012 Annual Review Report. 

EPA followed three Quality Assurance Project Plans (QAPPs) to conduct the annual 

review steps and analyze existing data sources: the Revised Quality Assurance Project Plan for 

the 2009 Annual Screening-Level Analysis of TRI, ICIS-NPDES, and PCS Industrial Category 

Discharge Data (ERG, 2009) and the Draft Quality Assurance Project Plan for Use of the 

Existing Data in EPA’s Screening-Level Analyses for Review of Industrial Discharges (ERG, 

2011) and the Environmental Engineering Support for Clean Water Regulations Programmatic 

Quality Assurance Project Plan (PQAPP) (ERG, 2013a). The following sections provide 

information on the data needs and sources for the 2012 Annual Review, and an evaluation of the 

data quality for each data source identified and used in the 2012 Annual Review. 

B-1 
Appendix B–Quality Assurance Activities Supporting The 2012 Annual Review Report

B.3 Data Needs and Sources

EPA used the following data sources to characterize wastewater discharges during the 

2012 Annual Review: 

• Enforcement and Compliance History Online (ECHO)/Online Tracking 

Information System (OTIS).

• Supporting documentation to the Office of Air Quality Planning and Standards 

(OAQPS) Regulations: National Emission Standards for Hazardous Air Pollutants 

(NESHAP) and New Source Performance Standards (NSPS).

• Conference proceedings, water-related journals, industry-specific organization 

literature.

• Data provided by trade association contacts.

• State regulatory agency data.

• Data obtained directly from industry. 

• Purdue University Calumet Water Institute-Argonne National Laboratory Task 

Force (Purdue-Argonne Task Force) Report.

• Steam Detailed Study Report (DSR).

• Targeted National Sewage Sludge Survey (TNSSS). 

• EPA, state, and local government representative data and information. 

• EPA Office of Water, Office of Ground Water and Drinking Water (OGWDW), 

and Office of Research and Development (ORD) Analytical Methods.. 

• EPA Office of Pollution Prevention and Toxic Substances (OPPT) program data 

sources: Chemical Action Plans (CAPs), Significant New Use Rule (SNUR).

• Office of Environmental Information (OEI) Toxic Release Inventory (TRI) 

Sectors Expansions Rulemaking Data. 

• Perfluoroctanoic acid (PFOA) data sources: OPPT PFOA Stewardship Program, 

Long-Chain Perfluorinated Chemicals (PFCs) public docket. 

• Office of Ground Water and Drinking Water (OGWDW) Drinking Water 

Treatability Database.

In addition, EPA used TRI and discharge monitoring report (DMR) data during the 2012 

Annual Review. EPA documents quality assurance and criteria in the Revised Quality Assurance 

Project Plan for the 2009 Annual Screening-Level Analysis of TRI, ICIS-NPDES, and PCS 

Industrial Category Discharge Data (ERG, 2009). 

B.4 Data Quality Criteria

EPA used existing data to support analyses of the impact of industrial discharges on the 

environment. These analyses relied on published literature identified during review of materials 

related to the targeted analyses. EPA obtained the existing data from publications and databases 

B-2 
Appendix B–Quality Assurance Activities Supporting The 2012 Annual Review Report

available from other EPA offices, www.regulations.gov, and other websites, as well as directly 

from industry and regulators (including EPA representatives). EPA considered the accuracy, 

reliability, and representativeness of data sources to assess their usability as follows.

Accuracy. EPA assumed that the underlying data and information contained in state and 

federal reports, selected conference proceedings, and peer-reviewed journal articles were 

accurate. That is, EPA assumed that data from these sources were of sufficient quality to identify 

characteristics of industrial discharges and that known analytical methods were used for any 

pollutant measurements.

Reliability. During the review of existing literature, EPA encountered sources that 

contained limited documentation of actual measurements, and instead provided qualitative 

discussion. For example, numerous media articles state that perfluorinated chemicals cause 

cancer, but the articles do not cite the source for the statement, do not provide numerical 

measurements of cancer incidence (increased risk), and do not provide amounts of exposure 

(such as mg/kg). These data sources represented a lower level of reliability than peer-reviewed 

literature, but provided useful information for capturing the full range of environmental impacts 

associated with industrial discharges. EPA also evaluated existing data for use in qualitative 

analyses for reliability based on the following factors: 

• The scientific work is clearly written, so that all assumptions and methodologies 

can be identified.

• The variability and uncertainty (quantitative and qualitative) in the information or 

in the procedures, measures, methods, or models are evaluated and characterized.

• The assumptions and methodologies are consistently applied throughout the 

analysis as reported in the source.

• Wastestream, parameters, units, and detection limits (when appropriate) are 

clearly characterized.

Representativeness. EPA evaluated existing data for use in qualitative analyses based on 

whether the data provide a national perspective and are relevant to and representative of the 

industry to which the data are applied. Specifically, EPA evaluated the data for the presence of 

the following information (as applicable to the relevant data sources):

• Actual facility wastewater discharge data (using EPA approved analytical 

methods). 

• Wastewater impacts directly related to air regulations (as stated in air regulation 

documentation). 

• Wastewater treatment effectiveness. 

• Flow and concentration data (types of pollutants and corresponding loads) of 

wastewater discharges to surface water bodies and publicly owned treatment 

works (POTWs).

• Industry process information (e.g., how is the pollution generated?). 

• Fate of biosolids in wastewater treatment.

B-3 
Appendix B–Quality Assurance Activities Supporting The 2012 Annual Review Report

• Information (qualitative and quantitative) about the manufacture of chemicals.

• Amount of pollutants in the United States and its effects on human health. 

B.5 Evaluating Data Quality 

This section describes the sources and summarizes how data sources met (or did not 

meet) the evaluation criteria listed above. Table B-1 at the end of this section details the criteria 

applied and the conclusions reached on each data source.

B.6 ECHO/OTIS

The ECHO/OTIS databases provide inspection, violation, and enforcement data for the 

CWA, Clean Air Act, and hazardous waste laws. The OTIS database is a collection of search 

engines that provides government agencies with access to a wide range of data. The ECHO 

database provides the general public with access to similar data. For its annual reviews, EPA 

extracted industrial discharge data from OTIS CWA reports. The underlying data in the 

ECHO/OTIS databases are from facility DMRs. While errors in data transcription and units 

errors are possible, the data are based on industry self-monitoring (DMR data), which specify 

analytical methods and are monitored in accordance with NPDES permitting requirements. EPA 

considered this data usable to characterize wastewater, evaluate industrial sector trends, and 

estimate pollutant loads.

B.7 OAQPS Regulations: NESHAP and NSPS

OAQPS compiled data in support of promulgating air regulations that include NESHAP 

and NSPS. These documents discuss industry profile information, manufacturing data, and, for 

some industries, an evaluation of changes in wastewater characteristics due to air pollution 

control. EPA evaluated supporting documentation for rules promulgated after 1990, including 

data published in the Federal Register (FR). In some cases, the rules supplemented older rules 

from the 1970s or 1980s, and EPA reviewed the older documentation as well. These documents, 

including citations supporting statements of fact, are written clearly. Overall, EPA considered 

these data accurate, reliable, and representative, and therefore usable to identify industrial sector 

trends and to qualitatively evaluate wastewater characteristics. These data were not used to 

calculate pollutant loads.

B.8 Conference Proceedings, Water-Related Journals, Industry-Specific Organization 

Literature

EPA is collecting, reviewing, and compiling into a searchable database data on the 

performance of new or improved wastewater treatment technologies. EPA obtained data from 

conference proceedings, water-related journals, and literature from industry-specific 

organizations. Section 6.6.1.3 of this 2012 Annual Review Report (Data Quality Assurance and 

Control Criteria) specifically discusses the data quality assurance criteria and methodology EPA 

used to conduct a literature review and develop the industrial wastewater treatment technology 

database. For more information on EPA’s efforts to ensure that the data sources meet the data 

quality criteria, see the methodology documented in the Supplemental Quality Assurance and 

Control Plan for the Development and Population of the Industrial Wastewater Treatment 

Technology Database (ERG, 2013b). 

B-4 
Appendix B–Quality Assurance Activities Supporting The 2012 Annual Review Report

B.9 Trade Association Data 

EPA obtained facility information from two trade associations in the 2012 Annual 

Review: the National Council for Air and Stream Improvement, Inc. (NCASI) and the American 

Forest & Paper Association (AF&PA). The trade associations gathered wastewater discharge 

data directly from facilities and provided results of dioxin analyses to EPA, including sample 

detection limits. EPA determined these data were usable for computing pollutant loadings. The 

trade associations also provided EPA with updates on the pulp and paper plants’ bleaching 

processes, which EPA found usable for characterizing industry practices.

B.10 State Regulatory Agency Data 

State regulatory agency data used in the 2012 Annual Review include data from the 

Nebraska Department of Environmental Quality, Illinois Environmental Protection Agency, 

North Carolina Department of Environment and Natural Resources, Virginia Department of 

Environmental Quality, Michigan Department of Environmental Quality, Pennsylvania 

Department of Environmental Protection, Texas Commission on Environmental Quality, Iowa 

Department of Natural Resources, and Alabama Department of Environmental Management. The 

state regulatory agencies gathered wastewater discharge data directly from facilities. EPA 

obtained DMRs, permits, fact sheets, and data from knowledgeable government representatives. 

The DMRs are certified by the facilities submitting them. Permits and fact sheets are factual 

documents containing well-documented information and are also accurate, reliable, and 

representative. EPA determined that general data provided by government representatives was 

useable for discharge characterization, permit limit comparison, and pollutant loads estimation.

B.11 Data Obtained from Industry

Specific facilities that were contacted during the 2012 Annual Review provided 

wastewater discharge data to EPA. EPA required that the discharge data include units, analytical 

method, detection limit information, and identifying data (date, outfall, etc.). EPA determined 

these data were usable for calculating pollutant loadings, wastewater characterization, industrial 

sector trends, and performance/efficiency.

B.12 Purdue-Argonne Task Force Report

The Purdue-Argonne Task Force collected data on treatment technologies that could help 

the BP Whiting (Indiana) Refinery meet wastewater discharge permit limits, such as the use of 

ultrafiltration treatment for mercury. The Task Force Report is a summary of a series of 

published documents that have undergone extensive review by multiple authors and include 

citations as backup documentation. EPA determined that this is a reliable, accurate, and 

representative source for evaluating the treatability of certain pollutants in petroleum refining 

wastewater, as well as for evaluating treatment effectiveness.

B.13 Steam DSR

The Steam DSR includes data documenting the performance of chemical precipitation 

and biological treatment at power plants, specifically of flue gas desulfurization wastewater 

treatment systems. This report also contains information on the evaluation of the industry profile 

for the steam electric power generating industry, including information on steam generating units 

B-5 
Appendix B–Quality Assurance Activities Supporting The 2012 Annual Review Report

that do not produce electric power for distribution and/or sale as their primary purpose. This 

report is a published EPA document, has undergone extensive review by multiple authors, and 

includes citations as backup documentation. EPA determined that this is a reliable, accurate, and 

representative source for evaluating treatment system performance.

B.14 TNSSS

The TNSSS includes three published EPA documents that have gone through extensive 

review: a summary document, a document that provides details on sampling techniques and 

location, as well as analytical methods, and a document on statistical analyses of the data. The 

three published documents state how pollutants were selected for analysis, list sampling 

techniques performed, interpret analytical results, and provide in-depth statistical analyses. 

Because the survey was performed on sludge, the data do not represent wastewater 

characteristics. However, when combined with toxic release inventory (TRI) data, the TNSSS 

data can provide useful information on how pollutants in industrial wastewater partition to 

sludge. EPA found all documents to be accurate, reliable, and representative, and therefore 

usable for industrial sector trends, pollutant load considerations, and consideration of 

environmental fate of pollutants. 

B.15 EPA, State, and Local Government Representatives Data and Information 

As part of the 304m process, EAD collected data and information from EPA Regional 

and Headquarters offices, as well as state and local government representatives. EPA considers 

these data useful for qualitative discussion, to provide general information on industrial sector 

trends. From discussions with government representatives, EPA often obtains published 

information; however, EPA evaluates the quality of this published information separately. 

B.16 EPA OW, OGWDW, and ORD Analytical Methods 

EPA periodically develops new or updates existing analytical methods in response to 

developments such as the identification of a new class of pollutants, or if impairments to water 

bodies indicate the need for altered or new methods. Available analytical method information 

from three EPA offices was analyzed for the 2012 Annual Review: EPA’s Office of Water 

(OW), Office of Science and Technology, Engineering and Analysis Division; EPA’s OGWDW; 

and EPA’s Office of Research and Development (ORD). 

The OW Analytical 2012 Method Update Rule provides a comprehensive list of updates 

to 40 CFR Part 136. The OGWDW Unregulated Contaminant Monitoring Rule (UCMR) 

provides a comprehensive list of new contaminants that drinking water utilities will analyze and 

report. ORD develops new analytical methods for drinking water and a variety of other emerging 

pollutants of concern. EPA considers all of these data sources to be accurate, reliable, and 

representative regarding the latest changes in analytical methods for wastewater and 

developments in drinking water, respectively. 

EPA did not use the data or information obtained from its review of analytical methods to 

evaluate specific industrial discharges or pollutant loads. Instead, EPA evaluated the information 

to assess new analytical methods or changes to existing analytical methods that may help EPA 

identify new pollutants of concern or strengthen existing requirements for regulated pollutants in 

industrial wastewater discharge. 

B-6 
Appendix B–Quality Assurance Activities Supporting The 2012 Annual Review Report

B.17 OPPT Data Sources: CAPs and SNUR

OPPT data sources (CAPs and SNUR) are published government documents that have 

undergone extensive review by multiple authors. EPA CAPs summarize available hazard, 

exposure, and use information for each chemical; outline the risks that each chemical may 

present; and identify the specific steps OPPT is taking to address those concerns. A SNUR is a 

regulation that requires manufacturers who intend to use a chemical for the identified significant 

new use to submit an application to the Agency for review prior to beginning that activity. EPA 

determined that these data are accurate, reliable, and representative. EPA determined these data 

are usable for documenting the manufacture, import, or processing of chemicals. When chemical 

release data are included in the documentation associated with these reports, EPA determined 

that they are usable for characterizing wastewater discharges.

B.18 OEI TRI Sectors Expansions Rulemaking Data

OEI initiated a rulemaking to add or expand the coverage of TRI for six industries in June 

2011. OEI published information about the proposed rulemaking at www.regulations.gov (TRI 

Exchange: http://exchange.regulations.gov/topic/trisectorsrule/agencyintro/tri-exchange) and 

asked for public comment on the six industries considered as part of the expansion. EPA 

considers these data useful for qualitative discussion to provide general information on the 

industries considered as part of the expansion. 

B.19 PFOA Data sources: OPPT PFOA Stewardship Program, PFCs Public Docket

OPPT’s PFOA Stewardship Program was developed to help minimize the potential 

impact of PFOA in the environment by asking manufacturing companies to commit voluntarily 

to reducing PFOA emissions and product content by 95 percent by 2010. Additionally companies 

that chose to participate in the program would work to eliminate PFOA emissions and product 

content by 2015. EAD collected publicly available data characterizing PFCs in industrial 

discharges by reviewing the docket supporting the PFOA enforceable consent agreement (ECA) 

process (available in docket EPA-HQ-OPPT-2003-0012). These backup data vary in content and 

quality. EPA found that monitoring data submitted by facilities were usable for characterizing 

wastewater and estimating pollutant loads, as long as analytical methods and sampling details 

were provided. 

B.20 OGWDW Drinking Water Treatability Database 

OGWDW's Drinking Water Treatability Database presents information on technologies 

that treat contaminants in drinking water. Its many uses include identifying effective treatment 

processes, planning for future treatment plant upgrades, and recognizing research needs. The 

database is published by EPA and undergoes review prior to release. Data characterize 

treatability levels for drinking water. This may not be representative of how technologies will 

perform on industrial wastewater. As a result, the TDB data are considered accurate and reliable, 

and therefore usable to qualitatively discuss treatability of compounds. For example, the 

treatability database shows that PFOA is not removed by biological treatment and may actually 

form during biological processes; whereas granular activated carbon (GAC) and ultraviolet 

irradiation, at wavelengths in the 185–200 nm range, remove PFOA. Although these 

observations relate to drinking water treatment, the same chemical processes would occur in 

wastewater treatment.

B-7 
Appendix B–Quality Assurance Activities Supporting The 2012 Annual Review Report

B.21 References for Quality Assurance Activities Supporting the 2012 Annual Review 

Report

1. ERG. 2009. Revised Quality Assurance Project Plan for the 2009 Annual ScreeningLevel Analysis of TRI, ICIS-NPDES, and PCS Industrial Category Discharge Data. 

(September). EPA-HQ-OW-2008-0517-0507. 

2. ERG. 2011. Draft Quality Assurance Project Plan for Use of the Existing Data in EPA’s 

Screening-Level Analyses for Review of Industrial Discharges. (October). EPA-HQ-OW2010-0824. DCN 07752. 

3. ERG. 2013a. Eastern Research Group, Inc. Environmental Engineering Support for Clean 

Water Regulations Programmatic Quality Assurance Project Plan (PQAPP). Chantilly, 

VA. (May). EPA-HQ-OW-2010-0824. DCN 07754. 

4. ERG. 2013b. Eastern Research Group, Inc. Supplemental Quality Assurance and Control 

Plan for the Development and Population of the Industrial Wastewater Treatment 

Technology Database. Chantilly, VA. (November 22). EPA-HQ-OW-2010-0824. DCN 

07753. 

5. U.S. EPA. 2012. The 2011 Annual Effluent Guidelines Review Report. Washington, D.C. 

(December). EPA-821-R-12-001. EPA-HQ-OW-2010-0824-0195. 

B-8 
Appendix B–Quality Assurance Activities Supporting The 2012 Annual Review Report

Table B-1. Data Sources Supporting New Analyses

Data source

Data Quality Criteria Conclusions on 

Accuracy Reliability Representativeness Usability

ECHO/OTIS Industry self 

monitoring data 

(DMR data), which 

specify analytical 

methods and are 

monitored in 

accordance with 

NPDES permitting 

requirements.

The data are 

clearly written 

and variability 

and uncertainty 

can be evaluated 

and addressed 

through outlier 

analyses and 

comparisons to 

permit limits.

Data are directly 

representative of 

wastewater discharges 

because the data are based 

on actual facility 

wastewater measurements 

using EPA approved 

analytical methods.

Data are accurate, 

reliable, and 

representative, and 

therefore usable to 

characterize 

wastewater, evaluate 

industrial sector 

trends, and estimate 

pollutant loads.

OAQPS 

Regulations: 

NESHAP, NSPS

The regulations and 

supporting 

documentation cite 

published data and 

reports. 

The regulations 

and supporting 

documentation are 

clearly written 

and document 

assumptions. 

In some cases, the 

regulations listed 

wastewater impacts, 

although regulations were 

for air discharges. EPA 

found the supporting data 

usable to identify 

potential pollutants 

transferred to wastewater 

due to air pollution 

control, and in cases 

where wastewater impacts 

were listed, identified 

likely pollutants 

transferred to wastewater.

Data are accurate, 

reliable, and 

representative, and 

therefore usable to 

identify industrial 

sector trends and to 

qualitatively evaluate 

wastewater 

characteristics. These 

data were not used to 

calculate pollutant 

loads.

Conference 

Proceedings, 

Water-Related 

Journals, and 

Industry-Specific 

Organization 

Literature

See Supplemental Quality Assurance and Control Plan for the Development and Population of 

the Industrial Wastewater Treatment Technology Database (ERG, 2013b) 

Trade 

Association Data:

American Forest 

and Paper 

Association 

(AF&PA) and the 

National Council 

for Air and 

Stream 

Improvement 

(NCASI)

Data are obtained 

from the facility 

that provided 

backup 

documentation, 

including sample 

detection limits.

Facilities 

provided detailed 

documentation of 

actual 

measurements 

gathered and any 

assumptions and 

methodologies.

Data are directly 

representative of 

wastewater discharges 

because the data are 

actual facility wastewater 

measurements. The trade 

associations also provided 

EPA with updates on the 

pulp and paper plants’ 

bleaching processes.

Data are accurate, 

reliable, and 

representative, and 

therefore usable for 

estimating pollutant 

loads and 

characterizing 

industry practices.

B-9 
Appendix B–Quality Assurance Activities Supporting The 2012 Annual Review Report

Table B-1. Data Sources Supporting New Analyses

Data source

Data Quality Criteria Conclusions on 

Accuracy Reliability Representativeness Usability

State Regulatory 

Agency Data

EPA obtained 

DMRs, permits, 

fact sheets, and data 

from 

knowledgeable 

government 

representatives. The 

DMRs are certified 

by facilities 

submitting them. 

Permits and fact 

sheets are factual 

documents 

containing welldocumented

information.

DMRs include 

actual pollutant 

measurements 

certified by 

facilities, 

including 

analytical method 

and detection 

limits. Facility 

permits and fact 

sheets are factual 

documents 

containing welldocumented 

information.

Data are directly 

representative of 

wastewater discharges 

because the data include 

actual facility wastewater 

measurements.

Data are accurate, 

reliable, and 

representative, and 

therefore usable for 

discharge 

characterization, 

permit limit 

comparison, and 

pollutant loads 

estimation. 

Data Obtained 

from Industry

Data received from 

facilities included 

units, analytical 

methods used, 

detection limit 

information, and 

identifying data. 

EPA only 

accepted data that 

was clearly 

written, and 

where variability 

and uncertainty 

could be 

evaluated and 

addressed through 

outlier analyses 

and comparisons 

to permit limits.

Data are directly 

representative of 

wastewater discharges 

because the data are 

actual facility wastewater 

measurements.

Data are accurate, 

reliable, and 

representative, and 

therefore usable for 

updating databases of 

DMR data, calculating 

pollutant loadings, 

wastewater 

characterization, 

industrial sector 

trends, and 

performance/ 

efficiency.

Purdue-Argonne 

Task Force 

Report

Report is a series of 

published 

documents that 

have undergone 

extensive review by 

multiple authors 

and include 

citations as backup 

documentation. 

Report contains 

detailed 

documentation of 

actual 

measurements, is 

clearly written, 

and documents 

assumptions and 

methodologies.

Data are directly 

representative of 

wastewater discharges 

because the data are based 

on actual facility 

wastewater 

measurements. Treatment 

system performance data 

are based on actual 

wastewater 

measurements, as well.

Data are accurate, 

reliable, and 

representative, and 

therefore usable for 

both estimating 

pollutant loads and 

treatment system 

performance.

B-10 
Appendix B–Quality Assurance Activities Supporting The 2012 Annual Review Report

Table B-1. Data Sources Supporting New Analyses

Data source

Data Quality Criteria Conclusions on 

Accuracy Reliability Representativeness Usability

Steam Detailed 

Study Report

Report has 

undergone 

extensive review by 

multiple authors 

and includes 

citations as backup 

documentation.

Data are 

published in an 

EPA document 

supporting a 

rulemaking.

Data report on wastewater 

treatment effectiveness 

for metals in industrial 

wastewater. Wastewater 

characteristics may be 

specific to steam electric 

generating facility 

discharges, but are 

representative of a sector 

of industrial wastewater 

discharges.

Data are accurate and 

reliable and therefore 

usable for 

documenting 

wastewater treatment 

technology 

effectiveness; 

however, EPA 

describes the data 

limitations. That is, 

EPA recognizes the 

treatment 

effectiveness may 

differ between 

industrial categories.

EPA’s Targeted 

National Sewage 

Sludge Survey

(TNSSS) 

The three TNSSS 

reports are 

published EPA 

documents that 

have gone through 

extensive review, 

and the data 

collection and 

analysis are 

covered by an EPA 

QAPP.

Data are clearly 

written, and all 

assumptions and 

methodologies 

were reported in 

the source. The 

reports list 

sampling 

techniques 

performed, 

interprets 

analytical results, 

and provides indepth statistical 

analyses. 

EPA recognizes that 

industrial users are not 

identified in the TNSSS 

which is a limitation of 

the data. However, data 

can be combined with 

TRI data to relate 

wastewater discharges to 

POTW sludge, and 

therefore are usable to 

investigate the fate of 

pollutants in POTWs. 

Data are accurate, 

reliable, and 

representative, and 

therefore usable for 

industrial sector trends 

and consideration of 

environmental fate of 

pollutants. 

B-11 
Appendix B–Quality Assurance Activities Supporting The 2012 Annual Review Report

Table B-1. Data Sources Supporting New Analyses

Data source

Data Quality Criteria Conclusions on 

Accuracy Reliability Representativeness Usability

EPA, State, and 

Local 

Government 

Representatives 

Data and 

Information

EPA regional and 

headquarters 

offices, and state 

and local 

government 

representatives 

provide information 

on programs at the 

federal, state, and 

local levels. For 

non-published 

material, such as 

historical program 

information 

provided from 

direct recall, EPA 

considers the 

information 

anecdotal. 

Historic and 

policy 

information about 

government 

programs is 

considered 

representative of 

the programs 

only, and not 

usable for 

characterizing 

industry 

discharges.

Information obtained 

from government officials 

is considered 

representative of 

government programs. 

Federal, state, and 

local representatives 

may provide program 

information that 

guides EPA research. 

For example, local 

pretreatment officials 

may provide anecdotal 

information on 

interferences, and 

EPA would pursue 

published reports on 

such interferences. 

The anecdotal 

information itself is 

not considered usable 

for characterizing 

wastewater 

discharges. EPA 

evaluates the quality 

of any published 

documents from 

federal, state, or local 

governments

separately (e.g., 

DMRs).

B-12 
Appendix B–Quality Assurance Activities Supporting The 2012 Annual Review Report

Table B-1. Data Sources Supporting New Analyses

Data source

Data Quality Criteria Conclusions on 

Accuracy Reliability Representativeness Usability

EPA Analytical 

Methods 

Published rules that 

demonstrate 

compliance or meet 

monitoring 

objectives for 

analytical 

measurement of 

substances in water. 

ORD and 

OGWDW focused 

on drinking water 

analysis; OW EAD 

focused on 

wastewater 

analysis.

Incorporate 

appropriate 

quality control 

criteria so that 

acceptable 

method 

performance is 

demonstrated 

during the 

analysis of 

samples.

Analytical methods 

related to wastewater are 

considered to be 

representative and useable 

for characterizing 

wastewater discharges. 

Analytical methods that 

evaluate drinking water 

may not work to evaluate 

industrial wastewater due 

to matrix interferences. 

However, EPA only used 

data and information to 

facilitate identification of 

new pollutants of concern 

in drinking water that may 

be attributed to industrial 

wastewater sources.

Data are considered 

accurate and reliable 

for the latest changes 

in analytical methods. 

Analytical methods 

for wastewater are 

representative for how 

well a contaminant 

can be measured, such 

as to which detection 

limit. Information on 

the detection limits 

achieved in 

wastewater 

measurements is 

usable for comparison 

with pollutant loads 

and wastewater 

characteristics. 

Information on 

drinking water 

methods is useable for 

identifying potential 

new pollutants of 

concern in drinking 

water from industrial 

sources.

OPPT Data 

sources: 

Chemical Action 

Plans (CAPs) and

Significant New 

Use Rules 

(SNURs) 

The data sources 

are published 

government 

documents that 

have undergone 

extensive review by 

multiple authors. 

Each CAP cites 

specific data 

sources, including 

peer-reviewed 

journal articles, 

technical 

encyclopedias, and 

chemical 

engineering 

textbooks. 

Data are clearly 

written, and all 

assumptions and 

methodologies are 

reported in the 

source. In cases 

where wastewater 

discharge data is 

provided, 

numerical 

measurements and 

units are 

provided.

Represent manufacturing 

processes of each 

chemical listed in the 

specific OPPT data 

source, as well as the 

environmental releases 

from the process. In some 

cases, provide qualitative 

discussion of resulting 

chemicals discharged in 

wastewater. In other 

cases, provide 

quantitative discussion of 

chemicals discharged in 

wastewater.

Data are considered 

accurate, reliable, and 

representative and 

therefore usable for 

documenting the 

manufacture, import, 

or processing of 

chemicals. When 

chemical release data 

are included in the 

documentation 

associated with these 

reports, they are 

usable for 

characterizing 

wastewater 

discharges.

B-13 
Appendix B–Quality Assurance Activities Supporting The 2012 Annual Review Report

Table B-1. Data Sources Supporting New Analyses

Data source

Data Quality Criteria Conclusions on 

Accuracy Reliability Representativeness Usability

OEI TRI Sectors 

Expansion 

Rulemaking (TRI 

Exchange)

Qualitative 

information on the 

six industries 

considered as part 

of the rulemaking 

was reviewed and 

published on EPA’s 

website.

Information is 

clearly presented 

and published on 

EPA’s website. 

Qualitative discussions on 

all six industries included 

as part of the rulemaking 

include information on 

industry profile, potential 

pollutants of concern, and 

information about 

potential impacts on 

wastewater. 

Data are considered 

accurate, reliable, and 

representative for a 

qualitative discussion 

on the six industries 

considered as part of 

the TRI Sectors 

Expansion. 

PFOA data 

sources: OPPT 

PFOA 

Stewardship 

Program, PFCs 

public docket

Supporting 

documentation for 

data varies in 

content and quality. 

Participating 

companies that 

provide data to 

EPA sometimes 

include analytical 

methods used and 

sampling details for 

the data submitted.

Data are certified 

as reliable by the 

companies 

submitting the 

data. 

Data are directly 

representative of 

wastewater discharges 

because the data are 

actual facility wastewater 

measurements.

Data are considered 

accurate, reliable, and 

representative and 

therefore usable for 

characterizing 

wastewater and 

estimating pollutant 

loads, as long as 

analytical methods 

and sampling details 

are provided.

OGWDW 

Drinking Water 

Treatability 

Database

The papers 

reviewed to create 

the EPA published 

database come from 

a wide range of 

peer-reviewed 

journals and 

conference 

proceedings, and 

also include theses 

and dissertations, 

handbooks, web 

pages, and trade 

publications.

Data are clearly 

written, and all 

assumptions and 

methodologies are 

reported in the 

source.

Data characterize 

treatability levels for 

drinking water. This may 

not be representative of 

how technologies will 

perform on industrial 

wastewater. 

Data are considered 

accurate and reliable, 

and therefore usable 

to qualitatively 

discuss treatability of 

compounds. For 

example, the 

treatability database 

shows that PFOA is 

not removed by 

biological treatment 

and may actually form 

during biological 

processes; whereas 

granular activated 

carbon (GAC) and 

ultraviolet irradiation, 

at wavelengths 

between 185–200 nm, 

remove PFOA. 

Although these 

observations relate to 

drinking water 

treatment, the same 

chemical processes 

would occur in 

wastewater treatment.

B-14