Environmental Protection: Wider Use of Advanced Technologies Can 
Improve Emissions Monitoring (22-JUN-01, GAO-01-313).		 
								 
The Environmental Protection Agency's (EPA) mission is to protect
human health and to safeguard the natural environment. This	 
includes regulating pollution generated by facilities such as	 
sewage treatment plants, power generation plants, chemical	 
manufacturers, and pulp and paper mills. Monitoring is a key	 
component of the efforts by both the government and private	 
parties to address these threats. Many of the technologies that  
are currently used to monitor environmental conditions have been 
in use for several decades. In recent years, however, a number of
technologies have been identified that may offer improved	 
measurement and performance capabilities. Concerned that many of 
these improved technologies are not being used to their full	 
potential, GAO's report (1) identifies technologies whose wider  
use can improve the monitoring of pollutants entering the	 
nation's air and water, (2) determines the extent to which these 
improved technologies are being used and steps that EPA can take 
to encourage their wider use, and (3) identifies the factors that
influence the development of new technologies and steps that EPA 
can take to encourage greater development of new technologies.	 
GAO found that several monitoring technologies exist that can	 
improve the capability to measure the emission or discharge of	 
pollutants from stationary air sources, wastewater sources, and  
nonpoint water sources. These technologies offer improvements	 
over older, more commonly used methods by detecting pollutants at
lower levels, reducing monitoring costs, and increasing the	 
reliability of monitoring results. GAO further found that the	 
primary barriers preventing wider use of these technologies	 
differ considerably across stationary air, wastewater, and	 
nonpoint water sources. Specifically, (1) entities responsible	 
for stationary air sources may not make greater use of advanced  
technologies because of their potential to identify instances of 
noncompliance and violations, (2) wastewater dischargers are not 
allowed to use the advanced technologies because EPA has yet to  
approve them for Clean Water Act compliance monitoring, and (3)  
entities responsible for nonpoint water sources have been	 
discouraged from using the technologies because of cost concerns.
Lastly, GAO found that equipment manufacturers tend to develop	 
new technologies only when strong prospects exist for a return on
their investments. Accordingly, many of the constraints that	 
impede the use of existing advanced monitoring technologies have 
limited such investments. Without regulatory requirements,	 
manufacturers have little incentive to bring new technologies to 
market. In the absence of private investment, EPA and other	 
agencies have sponsored some research in this area, but EPA has  
limited resources and research conducted by other agencies does  
not always provide results that are acceptable for regulatory	 
purposes.							 
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-01-313 					        
    ACCNO:   A01265						        
  TITLE:     Environmental Protection: Wider Use of Advanced	      
             Technologies Can Improve Emissions Monitoring                    
     DATE:   06/22/2001 
  SUBJECT:   Air pollution control				 
	     Environmental monitoring				 
	     Environmental research				 
	     Pollution monitoring				 
	     Research and development				 
	     Water pollution control				 
	     EPA Continuous Emissions Monitoring		 
	     Systems						 
								 
	     EPA Acid Rain Program				 
	     EPA Credible Evidence Rule 			 
	     EPA Environmental Technology			 
	     Verification Program				 
								 
	     EPA Maximum Achievable Technology			 
	     Standard						 
								 
	     EPA Total Maximum Daily Loads Program		 

******************************************************************
** This file contains an ASCII representation of the text of a  **
** GAO Testimony.                                               **
**                                                              **
** No attempt has been made to display graphic images, although **
** figure captions are reproduced.  Tables are included, but    **
** may not resemble those in the printed version.               **
**                                                              **
** Please see the PDF (Portable Document Format) file, when     **
** available, for a complete electronic file of the printed     **
** document's contents.                                         **
**                                                              **
******************************************************************
GAO-01-313
     
Report to Congressional Requesters

United States General Accounting Office

GAO

June 2001 ENVIRONMENTAL PROTECTION

Wider Use of Advanced Technologies Can Improve Emissions Monitoring

GAO- 01- 313

Page i GAO- 01- 313 Environmental Protection Letter 1

Executive Summary 2

Chapter 1 Introduction 11 Monitoring Facility Emissions Under the Clean Air
Act 12 Monitoring Discharges Under the Clean Water Act 12 The Search for
Improved Monitoring Technologies 14 Objectives, Scope, and Methodology 15

Chapter 2 Technologies for Measuring Emissions From Stationary Air Sources
18

Compliance Monitoring Under the Clean Air Act 18 Available Technologies That
Can Improve Monitoring of Air

Emissions 21 Extent to Which Improved Air Monitoring Technologies Are Being

Used 25 Factors That Influence Development of New Air Monitoring

Technologies 32 Conclusions 34 Recommendations 35 Agency Comments 35

Chapter 3 Technologies for Measuring Wastewater Discharges 37 Monitoring
Wastewater Discharges Under the Clean Water Act 37 Available Technologies
That Can Improve Wastewater Monitoring 39 Extent to Which Improved
Wastewater Monitoring Technologies

Are Being Used 41 Factors That Influence Development of Improved Wastewater

Monitoring Technologies 42 Conclusions 50 Recommendations 50 Agency Comments
51

Chapter 4 Technologies for Measuring Emissions From Nonpoint Water Sources
52

Monitoring and Assessing Nonpoint Sources of Water Pollution 52 Contents

Page ii GAO- 01- 313 Environmental Protection

Available Technologies That Can Improve Monitoring and Assessment 55 Extent
to Which Improved Nonpoint Source Monitoring

Technologies and Assessment Techniques Are Being Used 62 Factors That
Influence Development of Improved Nonpoint Source

Monitoring Technologies and Assessment Techniques 66 Conclusions 67
Recommendations 68 Agency Comments 68

Appendix I Comments From the Department of the Interior 69

Appendix II GAO Contact and Staff Acknowledgments 72

Tables

Table 1: Largest Stationary Sources of Criteria Pollutants (excluding lead)
and Volatile Organic Compounds, 1998 19 Table 2: Five Largest Major
Stationary Source Emitters of Toxic Air

Emissions, 1996 20 Table 3: Industrial Sources of Conventional and Toxic
Pollutants 38 Table 4: Examples of EPA Test Method Categories 39 Table 5:
Validation and Approval of Proposed Methods 44

Figures

Figure 1: Sources of Pollution 11 Figure 2: Example of a Continuous
Emissions Monitor 22 Figure 3: Overview of Advanced Air Monitoring
Technologies 24 Figure 4: EPA?s Office of Water Method Development Budget
for

Wastewater Monitoring 42 Figure 5: Nonpoint and Point Source Water Pollution
54 Figure 6: Examples of In- person Water Sampling Methods 57 Figure 7:
Examples of Remote Sensing 60

Page iii GAO- 01- 313 Environmental Protection Abbreviations

CEMS Continuous Emissions Monitoring Systems EPA Environmental Protection
Agency ETV Environmental Technology Verification GAO General Accounting
Office GIS Geographic Information Systems ICP/ MS Inductively Coupled
Plasma/ Mass Spectrometer OMB Office of Management and Budget PEMS
Predictive Emissions Monitoring Systems TMDL Total Maximum Daily Loads USGS
U. S. Geological Survey

Page 1 GAO- 01- 313 Environmental Protection

June 22, 2001 The Honorable Sherwood L. Boehlert The Honorable Cal Dooley
The Honorable James Greenwood House of Representatives

As requested, we are reporting on the use and development of monitoring
technologies for measuring emissions from stationary air, point water, and
nonpoint water sources of pollution.

As arranged with your offices, unless you publicly announce its contents
earlier, we plan no further distribution of this report until 30 days from
the date of this letter. At that time, we will send copies to the
appropriate congressional committees; the Honorable Christine Todd Whitman,
Administrator, EPA; the Honorable Gale Norton, Secretary of the Interior;
and the Honorable Mitchell Daniels, Director, Office of Management and
Budget. We will also post this report on the Internet at www. gao. gov and
make copies available to others upon request.

Please call me at (202) 512- 3841 if you or your staff have any questions.
Major contributors to this report are listed in appendix II.

John B. Stephenson Director, Natural Resources

and Environment

United States General Accounting Office Washington, DC 20548

Executive Summary Page 2 GAO- 01- 313 Environmental Protection

The U. S. Environmental Protection Agency (EPA) was established in 1970 to
consolidate in one agency a variety of federal research, monitoring,
standard setting, and enforcement activities to ensure environmental
protection. EPA?s mission is to protect human health and to safeguard the
natural environment. This includes regulating pollution generated by
facilities such as sewage treatment plants, power generation plants,
chemical manufacturers, and pulp and paper mills. Pollution can pose serious
threats to human health, wildlife, and other natural resources, and degrade
overall environmental conditions. Monitoring is a key component of the
efforts by both the government and private parties to address these threats.
Effective monitoring is critical to ascertain where the key pollution
problems exist, what their consequences may be, and how they can be most
effectively remedied. It is also an essential element of the government?s
efforts to determine compliance with existing laws and regulations. In
addition, monitoring has served in recent years as an essential ingredient
in regulatory flexibility efforts. Such efforts are intended to provide
regulated entities the flexibility to determine how they meet limits on the
pollutants they discharge, while ensuring through effective monitoring that
environmental standards are still met.

Many of the technologies that are currently used to monitor environmental
conditions have been in use for several decades. In recent years, however, a
number of technologies have been identified that may offer improved
measurement and performance capabilities. Concerned that many of these
improved technologies are not being used to their full potential, GAO was
asked to (1) identify technologies whose wider use can improve the
monitoring of pollutants entering the nation?s air and water; (2) determine
the extent to which these improved technologies are being used and steps
that EPA can take to encourage their wider use; and (3) identify the factors
that influence the development of new technologies and steps that EPA can
take to encourage greater development of new technologies. As agreed with
the Offices that requested this report, GAO focused its review on monitoring
technologies associated with air emissions from stationary sources,
wastewater discharges from ?point? water sources, and pollution from
diffused ?nonpoint? water sources.

While the Clean Air Act and the Clean Water Act each require facilities to
limit their pollutant discharges, the two federal environmental laws address
pollutant monitoring very differently. Under the Clean Air Act, EPA requires
about 20,000 of the largest pollution sources to obtain permits that
consolidate all applicable air pollution control requirements. Each permit
contains all required monitoring and analysis procedures. A Executive
Summary

Purpose Background

Executive Summary Page 3 GAO- 01- 313 Environmental Protection

limited number of facilities in certain industries must continuously measure
their emissions of some pollutants. Most other facilities, however, do not
and rely instead on short- term tests and other indicators of compliance. As
a result, regulators and regulated entities sometimes lack certainty about
whether these facilities maintain continuous compliance with clean air
regulations.

Facilities that discharge pollutants, or wastewater, into waters of the
United States from a discrete point, such as a pipe, are regulated by a
Clean Water Act program that requires facilities to monitor their discharges
in order to ensure compliance with pollutant discharge limits. Regulated
entities must use only EPA- approved test methods. The degree of monitoring
required depends on the type and amount of pollution that a facility emits.
However, there is a much greater degree of monitoring of pollutant
discharges from wastewater sources than from stationary air sources, mainly
because all wastewater sources that discharge into a body of water,
regardless of size, are required to have a pollutant discharge permit. There
are about 96,000 facilities that have a pollutant discharge permit under
this program.

Water pollution that cannot be traced to a pipe or other discrete conveyance
is known as ?nonpoint source? pollution. Nonpoint source pollution is caused
by such activities as agriculture, forestry, and urban development. The
diffuse nature of nonpoint sources makes their direct measurement
exceedingly difficult. Therefore, measuring nonpoint source pollution
entails analyses of multiple types of data, including water quality
conditions, land use, climate, and soil type. Mathematical models are often
used to translate these data into probable pollutant contributions from
individual sources or groups of similar types of sources. While nonpoint
sources, in general, are identified as contributors to most of the nearly
300,000 miles of rivers and streams and about 8 million acres of lakes that
do not meet water quality standards, there is no estimate for how many
sources actually contribute pollutants.

Efforts have long been underway to develop improved technologies to enhance
the monitoring of air and water quality. These efforts have generally sought
to (1) better enable regulators and regulated parties to detect pollution
problems and ascertain whether pollutant levels exceed regulatory standards,
(2) ascertain whether emitters are complying with specific limitations
listed in their permits, and/ or (3) reduce monitoring costs. Recent
proposals to allow regulated parties greater flexibility in achieving
emissions or discharge limitations have given the search for improved
monitoring technologies added impetus. One such proposal

Executive Summary Page 4 GAO- 01- 313 Environmental Protection

introduced in the 106th Congress was entitled, ?The Second Generation of
Environmental Improvement Act? (H. R. 3448). Among other things, the bill
would allow EPA to enter into ?innovative strategy agreements? with states,
companies, or other interested parties in order to achieve environmental
standards more efficiently and effectively. Such agreements could involve
the modification or waiver of agency regulations. Noting that such
regulatory flexibility should be accompanied by ?greater

accountability through enhanced monitoring and data reporting,? the bill
contained a number of provisions intended to improve monitoring and other
measurement methods.

A number of monitoring technologies exist that can improve the capability to
measure the emission or discharge of pollutants from stationary air sources,
wastewater sources, and nonpoint water sources. These technologies offer
improvements over older, more commonly used methods by detecting pollutants
at lower levels, reducing monitoring costs, and/ or increasing the
reliability of monitoring results. For example, Continuous Emissions
Monitoring Systems (CEMS) continuously measure pollutants released by
stationary air sources. EPA officials consider CEMS to be the most reliable
method for determining emissions. Promising wastewater monitoring
technologies include inductively coupled plasma/ mass spectrometry (ICP/ MS)
and ion chromatography, both of which can (1) detect pollutants at
significantly lower levels than commonly used monitoring technologies and
(2) reduce costs for users by rapidly analyzing multiple pollutants in a
single sample rather than analyzing them one at a time.

Most improved monitoring technologies have existed for years but are not
widely used. The primary barriers preventing wider use of these technologies
differ considerably across stationary air, wastewater, and nonpoint water
sources. Regarding emissions from stationary air sources, a major
disincentive to wider use of advanced technologies by regulated entities is
their potential to identify instances of noncompliance and violations. To
date, EPA requires only a limited number of industries (primarily electric
utilities) to use continuous emissions monitors. Regarding monitoring of
wastewater discharges, GAO found that the majority of dischargers are unable
to use advanced technologies, such as ICP/ MS, because EPA has yet to
specifically approve the technologies for Clean Water Act compliance
monitoring. Users cited a lengthy and cumbersome EPA approval process and
EPA?s funding constraints as the principal reasons why they do not more
widely use technologies such as the ICP/ MS and the ion chromatograph.
Regarding monitoring Results in Brief

Executive Summary Page 5 GAO- 01- 313 Environmental Protection

technologies for nonpoint water sources, while federal approval is not
needed, wider use of these technologies has been discouraged by concerns
over the cost of purchasing some of the technologies and the expertise
required to use them.

Equipment manufacturers develop new technologies only when strong prospects
exist for a return on their investments. Accordingly, many of the
constraints that impede the use of existing advanced monitoring technologies
have limited such investments. In the case of air monitoring technologies,
equipment manufacturers and regulators said that, without regulatory
requirements, manufacturers have little incentive to bring new technologies
to market. In the absence of private investment, government agencies,
including EPA, the Department of Defense, and the Department of Energy, have
sponsored some research in this area, but EPA has limited resources and
research conducted by other agencies does not always provide results that
are acceptable for regulatory purposes. Developers of wastewater monitoring
technologies have had some success in obtaining approval for minor
modifications to existing EPA methods as well as proposed methods to be used
by individual facilities. However, the approval process for major advances
with nationwide application has deterred investment in these more far-
reaching technologies.

Stationary sources of air pollution vary in the extent to which they monitor
their compliance with clean air regulations. Some of the largest emitters,
such as many electric utilities, must continuously monitor their emissions
of certain pollutants. Many sources, however, rely on other indicators of
compliance, such as short- term tests or periodic monitoring. As a result,
regulators and regulated entities sometimes lack certainty about whether
these facilities continuously comply with clean air regulations. Continuous
Emissions Monitoring Systems (CEMS) are capable of continuously measuring
and recording emissions of certain air pollutants using a variety of
sampling and analytical methods. EPA officials consider CEMS to be the most
reliable method for determining emissions. In addition to providing a
continuous indication of a facility?s compliance status, these devices can
provide facilities with information that enables them to identify process
improvements that could save them money and reduce emissions. Principal
Findings

Available Technologies Can Often Improve Monitoring and Reduce Costs

Executive Summary Page 6 GAO- 01- 313 Environmental Protection

In the case of wastewater discharges, ICP/ MS has long been recognized for
its potential to provide greater accuracy and, in some cases, to
dramatically lower costs. In fact, a 1988 EPA report predicted that during
the 1990s, ?the application of inductively coupled plasma/ mass spectrometry
to environmental analyses could result in the single greatest impact on the
analysis of metals.? Ion chromatography provides similar benefits when
measuring inorganic substances, such as nitrates and phosphates. Like ICP/
MS, it can rapidly analyze multiple pollutants in a single sample, as
opposed to methods currently used for wastewater monitoring that can analyze
only one pollutant at a time. As a result, ion chromatography can reduce
costs at commercial laboratories or large regulated facilities that test
numerous samples. In addition, ion chromatography has detection levels in
the parts- per- billion range, which is considerably lower than methods
currently in use.

The importance of identifying and measuring nonpoint sources of pollution
stems from intense pressure on the states and EPA to address the thousands
of waters that do not meet water quality standards as a result of these
sources. However, traditional water quality monitoring techniques, such as
in- person sampling, are too costly and labor- intensive to monitor a
sufficient number of waters. Technologies are available, however, that can
increase the amount of sampling that can be done and provide water quality
measurements more quickly. For example, some

?field- based? tools can take measurements of various water quality
parameters on- site, which eliminates certain laboratory analyses and
provides more immediate information. In addition, computerized models, which
automate the analysis of the complex relationships that define how water
pollutants move through the environment (an extremely difficult and time-
consuming analysis if conducted manually), have been made easier to use so
that more entities conducting nonpoint assessments can utilize these tools.

Many improved technologies have been used to only a limited extent despite
their proven track record. The reasons for this, however, vary among air,
wastewater, and nonpoint water monitoring technologies. A major barrier to
voluntary use of air emissions monitoring technologies by regulated entities
is the concern that improved monitoring will reveal violations of clean air
regulations that will result in punitive action. As a result, regulated
entities perform monitoring only when required to do so. EPA, however,
typically does not require emitters to use these technologies, due primarily
to time and resource constraints in issuing new regulations, as well as the
perception that they are too expensive. Improved Monitoring

Technologies Used to a Limited Extent

Executive Summary Page 7 GAO- 01- 313 Environmental Protection

The direct measurement of pollutant discharges from wastewater sources is
significantly greater than from stationary air sources, stemming largely
from a Clean Water Act program?s requirement that virtually all wastewater
sources that discharge pollutants into U. S. waters monitor their compliance
with a discharge permit. Yet, while this more comprehensive monitoring
framework would appear to encourage use of improved technologies for
monitoring Clean Water Act compliance, GAO found that few regulated
dischargers use ICP/ MS or the ion chromatograph for this purpose, despite
the fact that these technologies are routinely used to monitor compliance
with the Safe Drinking Water Act. The main reason that many dischargers do
not use these technologies is because the monitoring methods are not yet
approved for use by EPA, meaning that a facility could be found in
noncompliance for using an unapproved method. And while EPA had proposed
approving the use of ICP/ MS and the ion chromatograph for wastewater
compliance monitoring in the mid- 1990s, agency officials said that funding
constraints prevented the agency from doing the additional validation
studies needed to support an approval decision. In particular, they pointed
out that the amount of funding devoted to developing and validating methods
for use in compliance monitoring has declined by over 50 percent since
fiscal year 1997.

It is difficult to determine the extent of a particular nonpoint source
water monitoring technology?s use because (1) the different entities doing
nonpoint assessments are free to use any technology they choose and (2)
there is a multitude of ongoing nonpoint source pollution assessments across
the country. However, based on discussions with a diverse group of
participants in this type of monitoring and assessment, it appears that cost
and simplicity are major factors that influence their use. Hence, most
states are using automatic samplers and field- based analytical devices to
meet at least some of their monitoring and assessment requirements because
the technologies are relatively affordable and easy to use. Similarly,
states doing nonpoint source water assessments use simplified models that
have been enhanced in recent years with improved interfaces and graphical
output.

On the other hand, Geographic Information Systems (GIS), remote sensing, and
highly complex models, are used to a much lesser extent. Many officials that
GAO contacted cited the cost of purchasing such technologies and the skills
needed to operate and maintain them as major barriers. Some officials added
that states may be unwilling to experiment with less- proven technologies
because of their programmatic demands to conduct a large number of
assessments within fairly tight timeframes.

Executive Summary Page 8 GAO- 01- 313 Environmental Protection

Thus, the most advanced nonpoint source monitoring technologies are used
more frequently by research organizations or in special projects conducted
by states or interagency programs. Many officials noted the benefits of
using any of these advanced technologies include collecting more reliable
information or conducting more complex analyses, which will ultimately help
them make more informed decisions regarding needed pollution controls.

According to air monitoring equipment manufacturers and regulators,
manufacturers have little incentive to bring new monitoring technologies to
market in the absence of an identified need to satisfy a regulatory
requirement. As a result, most improvements focus on making existing
monitoring methods more reliable and less expensive. Given the limited
private investment in this area, EPA?s Science Advisory Board recommended in
1995 that the agency support the development and commercialization of more
innovative CEMS and other technologies. According to agency officials, EPA
devotes a limited amount of funding to the development of advanced
technologies, but this focuses on agency research objectives rather than
bringing promising technologies to market. Other federal agencies also
perform research and development, but these efforts do not always provide
results that are acceptable for regulatory purposes.

Manufacturers and vendors of wastewater monitoring technologies cited as
their primary deterrent the time required to navigate their most significant
technological proposals- those involving major modifications or new
monitoring methods with nationwide application- through a complicated EPA
technical and administrative rulemaking process. Between fiscal years 1993
and 2000, EPA approved two such ?nationwide

use? methods, taking about 3 years for one and about 3-ï¿½ years for the
other. The sponsor of a third case, currently in the rule making process,
projects that the total period of review will be about 5 years before the
proposed method is published as a final rule. A wide variety of
organizations GAO contacted, including state regulatory authorities,
regulated entities, and equipment manufacturers, voiced concern over the
length of this process. Equipment manufacturers told GAO that the EPA review
process had at least partly influenced their decision to apply their water
monitoring technologies to other markets, such as the pharmaceutical and
biotechnology industries. Others told GAO that they are focusing more of
their attention on overseas markets. Factors Influencing the

Development of New Technologies

Executive Summary Page 9 GAO- 01- 313 Environmental Protection

Several factors limit the market for advanced technologies for use in
nonpoint source assessments. In particular, manufacturers told GAO that
since there are no specific requirements regarding how states must monitor
their waters, there is no clearly defined market for their products.
Compounding this risk is the relative scarcity of shared information between
the users and the developers of these technologies. Several officials that
GAO interviewed consistently stated that information sharing about past
successes and failures using certain technologies and techniques needs to be
improved. Without such information, it is difficult to know where additional
technologies are needed. Finally, investment in nonpoint source pollution
monitoring by the largest group of users- the states- has historically been
light, given their water programs? historic focus on wastewater sources.
Consequently, instrument manufacturers told GAO that they believe the market
for new products in this area is relatively limited.

Because monitoring requirements vary considerably for air, wastewater, and
nonpoint source water pollution, GAO makes separate recommendations to the
Administrator, EPA, at the end of chapters 2, 3, and 4, respectively. The
recommendations in chapter 2 identify steps that EPA should take to
encourage wider use of advanced air monitoring technologies. Recommendations
in chapter 3 focus on improving and maintaining EPA?s process for approving
new monitoring methods or modifications to existing ones for use in
wastewater compliance monitoring. The recommendation in chapter 4 addresses
the need for improved information sharing regarding successes and failures
of new monitoring technologies and assessment techniques given the
decentralized nature of nonpoint source pollution management.

GAO provided EPA and the Department of the Interior with a draft of this
report for review and comment. In its letter dated June 12, 2001, Interior
said that it agreed with the recommendation in chapter 4 that EPA develop a
clearinghouse and/ or locator for monitoring technologies and assessment
techniques that are used for assessing pollutant contributions from nonpoint
water pollution sources and developing Total Maximum Daily Loads. It
suggested, however, that the report note that to some extent, several
agencies have already moved in this direction through the establishment of a
National Environmental Monitoring Index, which falls under the auspices of
the interagency National Water Quality Monitoring Council. GAO added
language to this effect in chapter 4 and incorporated Recommendations

Agency Comments

Executive Summary Page 10 GAO- 01- 313 Environmental Protection

several other technical comments and clarifications suggested by the
Department.

EPA did not submit a formal letter but supplied GAO with individual comments
from several of the offices with jurisdiction over the issues discussed in
the report. Commenting on the report?s discussion of air monitoring
technologies, the Office of Air and Radiation said it believed that ?the
subject is covered accurately and the conclusions are fair.? The Office
provided a number of editorial comments, which were incorporated as
appropriate. The Office of Research and Development provided input from
several individuals within the office. Among the key themes from these
comments were that the report should provide more detailed information on
the range of available monitoring technologies, the type of improvements
that are necessary, and the benefits of improved monitoring. GAO believes
that it was limited in the level of detail the report should devote to these
matters by (1) the enormous range of technologies that address air,
wastewater, and nonpoint source water monitoring and (2) the need to devote
sufficient attention in the report to the legal and regulatory barriers
inhibiting wider use and development of such technologies, which was the
primary focus of the report. Other comments by reviewers from the Office of
Research and Development are discussed at the end of chapter 2. The EPA
Offices of Water and of Enforcement and Compliance Assurance also reviewed
the draft report but did not provide comments.

Chapter 1: Introduction Page 11 GAO- 01- 313 Environmental Protection

Sewage treatment plants, power generation plants, chemical manufacturers,
and pulp and paper mills are among the facilities that emit or discharge
various pollutants into the air and water. Urban development and agriculture
also contribute pollutants to our environment, although often in a much more
?diffused? manner (see fig. 1.) Pollutants from all of these facilities and
activities can pose serious threats to human health- sometimes immediately
upon contact when encountered in sufficient quantities; other times through
long- term exposure to smaller quantities. Many pollutants also damage
wildlife and other natural resources, and degrade overall environmental
conditions. The primary purpose of the Clean Air Act and the Clean Water Act
is to regulate emissions of these pollutants.

Figure 1: Sources of Pollution

Chapter 1: Introduction

Chapter 1: Introduction Page 12 GAO- 01- 313 Environmental Protection

The systematic monitoring of pollutants is an essential function under both
statutes. It is particularly critical in determining where the key pollution
problems lie, what their consequences may be, and how they can be most
effectively remedied through pollution control strategies. It is also an
essential element of the government?s efforts to determine compliance with
existing laws and regulations. In addition, monitoring has served in recent
years as an essential ingredient in innovative environmental protection
programs, such as emissions trading. Such efforts are intended to provide
regulated entities with flexibility in how they meet limits on the
pollutants they discharge, while ensuring through effective monitoring that
environmental standards are still met. While the monitoring requirements of
the Clean Air Act and the Clean Water Act share some similarities, there are
also important differences.

Facilities that emit pollutants into the air- generally referred to as

?stationary air sources?- must comply with the emissions limitations and
other provisions of the Clean Air Act. Under the act, EPA requires some
facilities to limit or control their emissions of certain pollutants and
monitor their compliance with applicable clean air regulations.

Compliance monitoring requirements for individual facilities depend on
factors such as the type of facility and the amount of pollution it emits.
Some sources, such as many electric utilities, must continuously monitor
their emissions of certain pollutants. Most sources, however, instead
perform temporary emissions tests when they first install pollution control
equipment. Some of these facilities may, but do not necessarily, undergo
additional temporary monitoring (or ?periodic monitoring?) at the discretion
of their state air pollution control agency. As a result, regulators and
regulated entities sometimes lack the certainty that these facilities
maintain continuous compliance with clean air regulations. An EPA
enforcement official said that, in general, regulated entities must maintain
continuous compliance with applicable requirements adopted and approved
under the Clean Air Act.

Facilities that discharge pollutants into waters of the United States from a
discrete point, such as a pipe, are referred to as ?wastewater dischargers.?
Facilities include industrial operations, such as coal mining or iron
manufacturers, or other operations, such as sewage treatment facilities.
These three categories of dischargers account for 95 percent of all
discharges. Under a Clean Water Act program, all wastewater dischargers
Monitoring Facility

Emissions Under the Clean Air Act

Monitoring Discharges Under the Clean Water Act

Chapter 1: Introduction Page 13 GAO- 01- 313 Environmental Protection

must obtain a permit that generally includes effluent limitations and
monitoring requirements. Regulated entities must use approved EPA methods
for monitoring that describe procedures for measuring pollutants. The degree
to which monitoring is required depends on the type and amount of pollution
a facility emits. Overall, wastewater dischargers are more likely to
regularly measure their emissions than are regulated air pollution sources.
This more comprehensive monitoring framework stems largely from the Clean
Water Act program?s requirement that virtually all wastewater sources
discharging pollutants into U. S. waters have a pollutant discharge permit,
regardless of size.

In addition to facilities that discharge pollutants directly to waters,
pollutants may also be discharged into waters by a wide variety of

?nonpoint sources? of pollution. Nonpoint sources are diffused sources
associated with land- based activities such as agriculture, timber
harvesting, and urban development. While these activities generate and
eventually discharge pollutants to waters, unlike wastewater sources, their
discharges do not go through a pipe or other discrete conveyance. The Clean
Water Act directs states to develop programs that address nonpoint source
pollution but provides no direction for the establishment of minimum
national controls and/ or monitoring that must be implemented, such as it
does for the control of wastewater. As a result, state laws and programs
bearing on nonpoint source water pollution vary widely.

Without a clearly identified source of discharge, the direct measurement of
pollutant contributions from nonpoint sources remains exceedingly difficult.
Assessing nonpoint source pollution entails synthesizing and analyzing
multiple types of data, including water quality conditions, land use,
climate, and soil type. Mathematical models are often used to translate
these data into probable pollutant contributions from individual sources or
groups of similar types of sources.

State agencies that regulate water quality typically take the lead in
monitoring for nonpoint source pollution. Because no specific program
requirements exist regarding monitoring, assessing, or controlling nonpoint
sources, the use of particular monitoring technologies or assessment
techniques is not strictly controlled- a major difference between this and
the monitoring of stationary air emissions and wastewater discharges. In
addition, numerous federal, state, local, and other organizations often
monitor water quality conditions and generate other types of data used in
nonpoint source analyses.

Chapter 1: Introduction Page 14 GAO- 01- 313 Environmental Protection

Efforts have long been underway to improve the ability of regulators and
regulated parties to detect pollution problems, ascertain whether pollutant
levels exceed regulatory standards, and reduce monitoring costs. Research
and development of advanced monitoring technologies is conducted by many
different organizations such as federal agencies, universities and other
research- oriented institutions, and private vendors of such technologies.

According to a 1998 Department of Commerce report, the business sectors most
related to environmental monitoring- analytical services, instruments, and
information systems- accounted for about 2 percent of the U. S.
environmental industry?s revenues ($ 4.3 billion out of $181 billion) in
1996. In that year, these sectors included 2,100 companies and over 42,000
employees. Air and water monitoring revenues accounted for a little more
than one- half of overall revenues for these sectors, about $0.9 billion and
$1.4 billion, respectively in 1996. The report noted that investment in the
environmental industry posed significant risks, stating that ?most investors
perceive the risks of environmental investment as especially difficult to
overcome, and believe that the environmental market is riskier than others.?
1

Recognizing the need to accelerate the development and commercialization of
improved environmental technologies, EPA established the Environmental
Technology Verification program in 1995. This program verifies the
performance of commercially ready technologies and, according to EPA,
provides independent and credible assessments to potential buyers. EPA
relies on various stakeholder groups to prioritize the technologies to be
analyzed. As of September 2000, the program had verified 111 technologies.

Recent proposals to allow regulated parties greater flexibility in achieving
emissions or discharge limitations have given added impetus to the search
for improved monitoring technologies. One such proposal, ?The Second
Generation of Environmental Improvement Act? (H. R. 3448), was introduced in
the 106th Congress. H. R. 3448 noted that ?Numerous studies have recommended
experimenting with performance- based regulatory approaches that provide
regulated entities with greater flexibility in

1 See Meeting the Challenge: U. S. Industry Faces the 21 st Century; The U.
S. Environmental Industry, Office of Technology Policy, U. S. Department of
Commerce (Sept. 1998). The Search for

Improved Monitoring Technologies

Chapter 1: Introduction Page 15 GAO- 01- 313 Environmental Protection

determining how to meet environmental standards.? The bill stated, however,
that such flexibility should be accompanied by ?greater

accountability through enhanced monitoring and data reporting.? Toward this
end, the bill contained a number of provisions intended to improve
monitoring and other measurement methods. 2

Members of Congress Boehlert, Dooley, and Greenwood asked us to (1) identify
technologies whose wider use can improve the monitoring of pollutants
entering the nation?s air and water; (2) determine the extent to which these
improved technologies are being used and steps that can be taken to
encourage their wider use; and (3) identify the factors that influence the
development of new technologies and steps that can be taken to encourage
greater development of new technologies. As agreed, our review focused on
monitoring technologies associated with stationary air emissions and both
wastewater and nonpoint source water discharges.

To address the first two objectives, we interviewed numerous representatives
of relevant government agencies and private organizations, reviewed existing
literature, and analyzed available EPA data. Of particular note, we
interviewed officials from EPA?s Offices of Water, Air and Radiation, and
Research and Development who are responsible for conducting research in
monitoring technologies, evaluating technologies developed by private
organizations, and implementing clean air and clean water programs. We also
obtained and analyzed available EPA data on the timeframes for making
decisions on proposals for using alternative technologies for compliance
monitoring. We also spoke with officials from EPA?s Office of Enforcement
and Compliance Assurance to better understand the effect of the agency?s
enforcement regulations and policies on the use of improved monitoring
technologies. In addition, we contacted officials from the U. S. Geological
Survey and the Department of Energy who are involved in conducting
environmental monitoring and sponsoring research in environmental monitoring
technologies.

2 Among other things, the bill?s section 106 provided that the EPA
Administrator establish a program to publicly recognize efforts to develop
and make more effective use of improved monitoring technologies and to
develop technologies and other methods that reduce the costs of collecting
or disseminating monitoring data. The bill also contained other requirements
intended to encourage EPA to reduce the time required to approve new
monitoring technologies and to expedite their deployment. Objectives, Scope,

and Methodology

Chapter 1: Introduction Page 16 GAO- 01- 313 Environmental Protection

We also contacted many public and private organizations that have either
developed improved monitoring technologies or have participated in decisions
affecting their use by regulated emitters of air and water pollutants. These
organizations include state environmental regulatory agencies, academic and
research institutions, standards boards, such as the American Society of
Testing and Materials, industry associations, and technology manufacturers
or vendors.

To obtain further insights into the extent to which these technologies are
being used, we obtained data from relevant agency databases that contain
information on regulated entities and, in some cases, monitoring
requirements and the technologies being used to meet them. We also
interviewed state and federal regulatory agencies and regulated entities to
gain their perspective on this issue.

We also interviewed representatives of regulated entities to better
understand the incentives and disincentives surrounding the use of improved
air and water monitoring technologies. In selecting these organizations, we
sought diversity in the size and type of facility and the nature of the
emissions discharged. To obtain more detailed insights and

?hands- on? information, we visited the Hampton Roads Sanitation District in
Hampton, Virginia, and Dominion Power?s Possum Point Power Plant in
Dumfries, Virginia. At each location, we examined the monitoring instruments
currently in use, and discussed with company officials the factors that
affected their decisions and their ability to use more advanced monitoring
methods.

To address the factors that affect the development of new monitoring
technologies, we concentrated mainly on the views of the instrument
manufacturers, public and private research organizations, and other
organizations whose decisions most directly influence the nature and extent
of investment in developing new monitoring technologies. We identified the
factors affecting their investment decisions, as well as the implications
these decisions would likely have on the future availability of improved
monitoring technologies. We also attended EPA?s annual conference on
monitoring technologies for various media, EPA?s national conference on
nonpoint source monitoring, and a conference on air monitoring technologies.

We conducted our work from September 2000 through May 2001 in accordance
with generally accepted government auditing standards.

Chapter 1: Introduction Page 17 GAO- 01- 313 Environmental Protection

Most GAO reports are organized in a manner that addresses each evaluation
question sequentially (as is done in the executive summary of this report).
However, the detailed information in the chapters of this report has been
structured somewhat differently because of the complexity of the
technologies discussed and the relatively unique issues concerning the
monitoring technologies associated with air, wastewater, and nonpoint source
water pollution. Accordingly, chapter 2 addresses the three evaluation
questions as they relate to stationary air pollution sources; chapter 3
addresses the three questions as they relate to wastewater pollution
sources; and chapter 4 addresses the questions as they relate to nonpoint
water pollution sources. Organization of This

Report

Chapter 2: Technologies for Measuring Emissions From Stationary Air Sources

Page 18 GAO- 01- 313 Environmental Protection

Regulated stationary sources of air pollution vary in the extent to which
they must monitor their emissions. Some sources, such as many electric
utilities, must continuously monitor their emissions of certain pollutants.
Most other facilities, however, do not and rely instead on short- term tests
and other indicators of compliance. As a result, regulators and regulated
entities sometimes lack certainty about whether these facilities maintain
continuous compliance with clean air regulations. Technologies are available
that could improve these facilities? capacity to monitor their air emissions
and their compliance with clean air regulations. Accordingly, our discussion
of advanced air monitoring technologies focuses on commercially available
technologies that can assist regulated entities in monitoring compliance.
These technologies can also help facilities better understand their
processes and identify opportunities to improve productivity and reduce
waste.

Despite these incentives, we found that regulated facilities generally
utilize advanced technologies only when required for regulatory purposes.
However, EPA rarely requires continuous compliance monitoring because of
time and resource constraints in issuing new rules, as well as the
perception that advanced monitoring technologies are too expensive.
Voluntary use of advanced technologies by regulated entities is also rare
because of the concern that improved monitoring will reveal violations of
clean air regulations. These factors limit not only the use of advanced
technologies, but also corporate investments in research and development of
new technologies.

The Clean Air Act is a comprehensive environmental law that regulates air
emissions from stationary and mobile sources. Under the act, EPA regulates
six ?criteria? pollutants to protect public health: carbon monoxide, lead,
nitrogen dioxide, particulate matter, sulfur dioxide, and ground- level
ozone. (The latter is not directly emitted by stationary sources, but forms
through the airborne reaction of heat and sunlight with nitrogen oxides and
volatile organic compounds.) In addition to the six criteria pollutants, EPA
regulates 188 hazardous air pollutants known as air toxics. People exposed
to toxic air pollution- which can be highly localized near industrial
sources- have an increased chance of getting cancer and other serious health
effects.

For the purposes of the Clean Air Act, stationary air pollution sources fall
into two categories: major sources and minor sources. Generally, major
sources are facilities that annually emit or have the potential to emit
Chapter 2: Technologies for Measuring

Emissions From Stationary Air Sources Compliance Monitoring Under the Clean
Air Act

Chapter 2: Technologies for Measuring Emissions From Stationary Air Sources

Page 19 GAO- 01- 313 Environmental Protection

annually (1) 10 or more tons of any one toxic air pollutant; (2) 25 tons of
any combination of toxic air pollutants, or (3) 100 or more tons of any of
the six criteria pollutants. 1 An EPA official said that, as of January
2001, there were approximately 20,000 major sources; EPA data show that
there were about 53,000 facilities classified as point sources in 1996. 2

Each year, industrial operations in the United States emit nearly 100
million tons of pollutants into the air. Table 1 shows the five largest
industrial sources of criteria pollutants (excluding lead) and volatile
organic compounds in 1998 (the most recent data available). Large stationary
sources accounted for 19 percent of total criteria pollutant emissions
(excluding lead) in 1998. Small stationary sources and mobile sources such
as cars, trucks, and buses accounted for the remaining 81 percent.

Table 1: Largest Stationary Sources of Criteria Pollutants (excluding lead)
and Volatile Organic Compounds, 1998

Source Level of emissions (tons)

Proportion of total from large stationary

sources (percentage)

Coal- powered electric utilities 18,377,073 52 Industrial fuel combustion
(coal, gas, and other) 5,333,899 15 Chemical manufacturing 1,961,876 6
Ferrous metal processing 1,756,146 5 Mineral products 1,004,962 3 Other
sources 6, 739,181 19

Total 35,173,137 100

Source: EPA

Table 2 identifies the five largest major source emitters of toxic air
emissions in 1996 (the most recent data available). Major sources accounted
for about 24 percent of the emissions of toxic air pollutants in 1996.

1 The definition of a major source also depends on the air quality in its
geographic area. For example, sources that emit as little as 10 tons a year
of volatile organic compounds may be classified as major sources in areas
with poor air quality.

2 EPA officials said that the agency does not maintain complete information
on the total number of minor sources.

Chapter 2: Technologies for Measuring Emissions From Stationary Air Sources

Page 20 GAO- 01- 313 Environmental Protection

Table 2: Five Largest Major Stationary Source Emitters of Toxic Air
Emissions, 1996 Source Level of emissions

(tons) Proportion of total from

major sources (percentage)

Utility boilers 408,747 36 Petroleum refineries 80,369 7 Pulp and paper
production 59,810 5 Metal parts coating 50,921 5 Polymer and resin
manufacturing 35,546 3 Other major sources 492,407 44

Total 1,127,800 100

Source: EPA

Some sources, such as many electric utilities, must measure their emissions
of certain pollutants continuously. Most sources, however, instead perform
temporary emissions tests to verify performance when they first install
pollution control equipment. Some of these facilities may, but do not
necessarily, undergo additional ongoing monitoring (or

?periodic monitoring?) of the pollution control measures at the discretion
of their state air pollution control agency. As a result, regulators and
regulated entities sometimes lack certainty about whether these facilities
maintain continuous compliance with clean air regulations. According to
EPA?s Office of Enforcement and Compliance Assurance, in general, regulated
entities must maintain continuous compliance with applicable requirements
adopted and approved under the Clean Air Act.

According to EPA officials, when facilities are required to measure
emissions for regulatory compliance, they must use EPA developed and
approved test methods (for periodic or continuous monitoring) or performance
specifications (for continuous monitoring). As of August 2000, EPA had
developed and approved 11 performance specifications covering a variety of
pollutants and continuous monitoring technologies. In addition, EPA has
developed and made available over 100 approved test methods that address the
criteria air pollutants and certain air toxics, such as mercury. 3 An EPA
official said that the agency also allows the submittal

3 According to EPA?s Office of Air and Radiation, methods for certain
pollutants do not apply to all sources. EPA said that, for example, the
agency has an approved method for monitoring mercury emitted by waste
combustors, but not from electric utilities.

Chapter 2: Technologies for Measuring Emissions From Stationary Air Sources

Page 21 GAO- 01- 313 Environmental Protection

of alternative test procedures and will approve these alternatives if the
agency determines that they provide an adequate level of certainty.

Overall, we found that commercially available technologies could assist in
monitoring compliance with clean air regulations and in identifying process
and efficiency improvements that could lead to decreased use of raw
materials and reduced emissions. Many of these technologies, including those
that monitor criteria and toxic air pollutants, provide continuous
measurement of emissions or operating parameters that correlate to
emissions.

EPA officials consider Continuous Emissions Monitoring Systems (CEMS) to be
the most reliable method for determining emissions. In contrast to periodic
monitoring, these devices continuously measure pollutants released by a
source. Some CEMS extract a gas sample from a facility?s exhaust and
transport it to a separate analyzer while others allow effluent gas to enter
a measurement cell inserted into a stack or duct (see fig. 2). Available

Technologies That Can Improve Monitoring of Air Emissions

Continuous Emissions Monitoring Systems

Chapter 2: Technologies for Measuring Emissions From Stationary Air Sources

Page 22 GAO- 01- 313 Environmental Protection

Figure 2: Example of a Continuous Emissions Monitor

According to EPA officials, CEMS that can measure certain pollutants, such
as carbon monoxide, hydrochloric acid, nitrogen oxides, sulfur dioxide, and
total organics, are commercially available and can meet requirements for
regulatory purposes. Continuous opacity monitors are also commercially
available and EPA has promulgated a performance

Evaluation of pollutant data for compliance Pollutant

analysis Pollutant

extraction

Chapter 2: Technologies for Measuring Emissions From Stationary Air Sources

Page 23 GAO- 01- 313 Environmental Protection

specification for their use. In addition, EPA has proposed, but not yet
promulgated, performance specifications for continuous measurement of
multiple metals, particulate matter, and mercury. 4 CEMS that monitor
multiple metals and particulate matter are commercially available in the
United States, while mercury CEMS are available in Asia and Europe.

Predictive emissions monitoring systems (PEMS) utilize data on operating
parameters (such as temperature, pollutant flow rates, and oxygen levels)
along with modeling software to predict emission levels. If predicted
emissions remain below allowable levels, it is then assumed that actual
emissions will remain under those levels. PEMS do not directly measure
emissions as CEMS do, but they do provide a continuous indication of a
facility?s compliance status. According to EPA officials responsible for
developing performance specifications, the agency allows the use of
predictive systems to demonstrate compliance with certain nitrogen oxide
regulations and the agency currently is developing a performance
specification for generic PEMS use.

At certain industrial facilities, such as petroleum refineries, fumes
leaking from pipes and other equipment (often referred to as fugitive
emissions) can account for a significant portion of overall emissions. EPA
requires almost all refineries to implement leak detection and repair
programs. Facilities that implement such programs must check for leaks using
a portable hydrocarbon monitor and repair the leaks that exceed specified
thresholds. Because of recent interest that government, industry, and
environmental groups have shown in identifying lower cost leak detection
programs, an EPA contractor recently prepared a report identifying
alternative technologies that could drastically lower implementation costs.
5 Some of the reviewed technologies involved remote detection rather than
use of portable monitors. The study found that annual costs of leak
detection programs using traditional portable monitors ranged from

4 According to EPA?s Office of Air and Radiation, the mercury specification
applies to municipal waste combustors, but not to coal- burning sources. 5
See Compendium of Sensing Technologies to Detect and Measure VOCs and HAPs
in the Air, Final Report, ICF, Inc., prepared for U. S. Environmental
Protection Agency and the Equipment Leaks Project Team (June 1999). These
technologies include Backscatter Absorption Gas Imaging, the Image Multi-
Spectral Sensing Infrared Camera, Open- Path Fourier Transform Infrared
Spectroscopy, Differential Optical Absorption Spectrometry, Tunable Diode
Laser Absorption Spectroscopy, and Light Detection and Ranging. Predictive
Emissions

Monitoring Systems Leak Detection Instruments

Chapter 2: Technologies for Measuring Emissions From Stationary Air Sources

Page 24 GAO- 01- 313 Environmental Protection

$90,000 (for two small refineries) to $344,000 (for a large refinery), while
the estimated annual costs associated with certain alternative technologies
ranged from $9,600 to $41, 000.

Figure 3 provides an overview of these advanced monitoring technologies.

Figure 3: Overview of Advanced Air Monitoring Technologies

Chapter 2: Technologies for Measuring Emissions From Stationary Air Sources

Page 25 GAO- 01- 313 Environmental Protection

We found that regulated facilities typically utilize advanced air monitoring
technologies only when the regulations require them. While regulated
entities have some incentive to use these technologies, such as the ability
to optimize their processes, the fear that improved monitoring will reveal
violations of clean air regulations often cancels out the incentives. While
EPA generally requires facilities to maintain continuous compliance with air
regulations, air emissions standards issued by the agency rarely require
facilities to perform continuous monitoring due to time and resource
constraints in issuing new rules, as well as the perception that available
technologies are too expensive.

EPA?s Office of Air and Radiation reported that most advanced monitoring
technology use stems from regulatory requirements. According to EPA
officials, the most widespread requirements for using advanced monitoring
technologies- specifically CEMS- stem from EPA?s Acid Rain program. This
program, established by title IV of the 1990 Clean Air Act Amendments,
requires reductions of nitrogen oxide and sulfur dioxide emissions from
electric utilities. The program also established an allowance trading system
that permits electric utilities to trade sulfur dioxide allowances. The
utilities must own enough allowances at the end of each year to cover the
emissions from the affected units. The program currently affects over 2,300
electric utility units nationwide. Between 1990 and 1999, facilities
participating in the program reduced their sulfur dioxide emissions by
approximately 21 percent. EPA describes the use of CEMS to measure nitrogen
oxide and sulfur dioxide emissions as critical to instilling confidence in
the program and ensuring that emissions reductions are met.

A similar trading program, which the South Coast Air Quality Management
District operates in Los Angeles, requires major sources to use CEMS to
determine their nitrogen oxide and sulfur oxide emissions. This program has
reduced the emissions of nitrogen oxides and sulfur oxides from
participating facilities by about 17 and 6 percent, respectively, between
1994 and 1998. A recent program audit described CEMS as the most accurate
and reliable method for direct determination of emissions. Lending further
support to the importance of CEMS in the success of emissions trading
programs, a recent National Academy of Public Administration study found
that the lack of CEMS use in trading programs involving volatile organic
compounds led to difficulty ensuring the certainty of emissions reductions.
Extent to Which

Improved Air Monitoring Technologies Are Being Used

Most Use of Advanced Technologies Stems from Regulatory Requirements

Chapter 2: Technologies for Measuring Emissions From Stationary Air Sources

Page 26 GAO- 01- 313 Environmental Protection

Certain federal requirements not associated with trading programs also
mandate CEMS use. For example, regulations that apply to some chemical
plants, incinerators, petroleum refineries, pulp mills, and sulfuric and
nitric acid plants require the use of CEMS. EPA has also required the use of
continuous opacity monitors in regulations for a variety of combustion,
materials handling, and smelting processes. EPA data show that at least
6,750 CEMS are used nationwide. 6 Approximately 80 percent of these are used
to monitor carbon monoxide, opacity, nitrogen oxides, and sulfur dioxide.
Less than 1 percent are used to monitor hydrocarbons and air toxics.

States also require advanced monitoring in certain circumstances. For
example, a Pennsylvania official said that the state requires 445 CEMS in
addition to 327 required by federal regulations. In addition, states can
foster the use of advanced technologies by specifying the technologies that
facilities can use to demonstrate compliance with certain regulations. For
example, Texas allows regulated entities to use CEMS or PEMS to monitor
compliance with certain regulations for nitrogen oxide emissions. A Texas
official said that this has led to the use of more than 100 PEMS in the
Houston area.

In addition, EPA and state agencies can, and sometimes do, require the use
of advanced monitoring technologies as part of settlement agreements at
facilities found noncompliant with air regulations. For example, in November
2000, EPA, the U. S. Justice Department, and the State of New York reached
an agreement with an electric utility to resolve Clean Air Act violations.
In addition to paying a $5.3 million civil penalty and reducing its
emissions of nitrogen oxides and sulfur dioxide, the utility agreed to
install advanced particulate matter continuous emission monitors.

In addition to their important role in emissions trading programs, advanced
monitoring technologies can help facilities better understand their
processes and identify opportunities to improve productivity and reduce
waste. For example, a monitoring consultant described a magnesium casting
company that monitored the loss of a sulfur compound (used to insulate
molten magnesium) in its processes using CEMS.

6 EPA officials said that this is the number of CEMS in use, not the number
of facilities using them. EPA?s compliance data administrator said that
states voluntarily report CEMS use data and that the actual number of CEMS
in use exceeds that reported. Use of Advanced

Technologies Can Lead to Cost Savings, Emissions Reductions, and Increased
Compliance

Chapter 2: Technologies for Measuring Emissions From Stationary Air Sources

Page 27 GAO- 01- 313 Environmental Protection

Through a 4- hour test, the company identified opportunities for increased
process efficiency that saved it hundreds of thousands of dollars per year
because of increased efficiency and decreased loss of raw materials.

Use of advanced monitoring technologies can also help facilities avoid
regulatory requirements. For example, an equipment vendor said that
facilities sometimes voluntarily use improved technologies to demonstrate
that their emissions remain below the thresholds that would otherwise
categorize them as a major (rather than a minor) air pollution source. Such
a demonstration allows these facilities to avoid the regulatory requirements
associated with major source status.

In addition to the benefits that advanced monitoring technologies can
provide regulated entities, their use in compliance monitoring has been
associated with increased rates of compliance and emissions reductions. For
example, a study conducted by EPA?s Midwest regional office involving data
from more than 1,100 facilities using advanced monitoring technologies, such
as CEMS and continuous opacity monitors, found that (1) these facilities
achieved a reduction in the number of instances where they reported excess
emissions and (2) the use of these technologies resulted in emissions
reductions.

Voluntary use of advanced technologies by regulated entities is a
doubleedged sword. On the one hand, it may reap cost savings and other
benefits. On the other hand, the technologies have the potential to reveal
instances of noncompliance and violations that could lead to punitive action
by EPA or interest groups. In particular, EPA officials told us that
improved monitoring technologies could identify violations of emissions
limits as well as the presence of pollutants that the regulated entity is
not allowed to emit.

At a recent conference on air pollution monitoring technologies, a regulated
entity and a monitoring consultant said that the ?Credible

Evidence? rule discourages the voluntary use of monitoring technologies. The
Clean Air Act authorizes EPA to bring an administrative, civil, or criminal
enforcement action ?on the basis of any information available to the [EPA]
Administrator.? According to an EPA enforcement official, in promulgating
the Credible Evidence rule in 1998, EPA sought to clarify the range of
information that regulators and regulated entities could use in determining
compliance with emissions limits. Importantly, this includes the use of
information obtained through advanced monitoring technologies such as CEMS
and PEMS. Increased Chance of

Identifying Violations Discourages Voluntary Use of Advanced Technologies

Chapter 2: Technologies for Measuring Emissions From Stationary Air Sources

Page 28 GAO- 01- 313 Environmental Protection

According to an EPA enforcement official, the agency has attempted to
mitigate these concerns about the voluntary use of monitoring technologies
and has offered reduced penalties for facilities that self- disclose
violations. In addition, EPA states in the rule?s preamble that the agency
focuses its judicial enforcement resources on large, significant cases
rather than relatively minor matters. Specifically, it said that the agency
focuses enforcement resources on violations that (1) may threaten or harm
public health or the environment, (2) are of significant duration or
magnitude, (3) represent a pattern of noncompliance, (4) involve a refusal
to provide requested compliance information, (5) involve criminal conduct,
or (6) allow a source to reap an economic windfall. The preamble also said
that EPA does not intend to foster frivolous lawsuits, and that it does not
expect that such lawsuits would result from the rule?s adoption.

Despite this, many of those we interviewed conveyed a widespread belief that
the rule continues to place emitters at risk for enforcement action. For
example, a monitoring consultant said that the rule stands as a major
barrier to more widespread voluntary use of advanced technologies, even
though certain technologies can help identify process improvements that
achieve cost and environmental benefits. He said that lawyers representing
regulated entities are concerned that data gathered through voluntary
monitoring could be used to show noncompliance. Similarly, a regulated
entity said that the Credible Evidence rule stands as the single biggest
barrier to performing voluntary monitoring with advanced technologies. EPA
Office of Air and Radiation officials agreed that the potential for a
facility to learn that it violates permit limits remains a major
disincentive to continuous monitoring. They also said that regulated
entities have little incentive to upgrade their monitoring technology and
that improved monitoring will not occur without regulatory requirements.

For EPA to require the use of monitoring technologies, it must first develop
approved test methods (for periodic or continuous monitoring) and
performance specifications (for continuous monitoring). According to the
Office of Air and Radiation, the development of performance specifications
requires data from field tests, which they do not have the resources to
conduct. Between 1995 and 2001, EPA?s annual budget to develop, evaluate,
and support emission testing and monitoring tools dropped from about $3,
947,000 to $1,440,000; a 64 percent reduction. 7 As a

7 Budget data were adjusted to account for inflation. All figures are in
2000 dollars. Cost Concerns Also Hinder

Use of Advanced Monitoring Technologies

Chapter 2: Technologies for Measuring Emissions From Stationary Air Sources

Page 29 GAO- 01- 313 Environmental Protection

result, EPA must rely on outside parties to provide the necessary data.
However, because EPA does not always participate directly in the testing,
the results may not be suitable for regulatory purposes. The official said
that EPA is still ?feeling its way? through its reliance on data from
external parties. An EPA official said that information gathered through the
agency?s ETV program can sometimes assist in developing performance
specifications and test methods.

In accordance with Executive Order 12866 and the Unfunded Mandates Reform
Act of 1995, EPA analyzes the costs, benefits, and alternatives to, certain
proposed regulations. However, according to an EPA air program official, the
agency does not have formal cost- benefit criteria for use in selecting the
compliance monitoring requirements that will accompany new rules. This
official and another EPA air official who commented on a draft of this
report said that the agency evaluates the costs of different compliance
monitoring options, and that agency staff use their judgment to determine
whether certain options impose excessive costs on affected sources.

The first official also said that when EPA promulgates many of its rules,
such as Maximum Achievable Control Technology regulations for certain
emitters of air toxics, it determines the level of pollution control that
facilities can achieve using available technologies. 8 It then generally
requires the affected facilities to control their emissions at certain
levels and monitor their compliance using the test method EPA used when it
originally tested facilities; in most cases, stack tests. While EPA?s
preference is for facilities to continuously monitor their compliance, EPA
officials said that, given the time and resource constraints associated with
the issuance of air quality regulations, the agency has decided not to spend
resources to evaluate alternative compliance monitoring options. EPA?s
Office of Air and Radiation said that the agency encounters less resistance
from industry when promulgating rules if it requires compliance monitoring
via the test method that the agency used to set the standard.

EPA air program officials also expressed concern over the reaction of the
Office of Management and Budget (OMB) to requirements to use advanced
technologies. They maintained that OMB generally views monitoring

8 The Clean Air Act specifies the methodology for determining the level of
pollution control that affected facilities must achieve to comply with
Maximum Achievable Control Technology standards.

Chapter 2: Technologies for Measuring Emissions From Stationary Air Sources

Page 30 GAO- 01- 313 Environmental Protection

requirements as a cost rather than a benefit, and that taking such
requirements out of rules can reduce drastically the overall costs to
industry. An EPA enforcement official said that, in promulgating rules, the
agency often has to compromise with OMB, and drops the monitoring
requirements as a result; despite the fact that emissions reductions have
been achieved at facilities required to use advanced monitoring
technologies. According to EPA?s Office of Air and Radiation, the agency has
yet to conduct a cost- benefit analysis to evaluate the advantages of using
CEMS rather than higher levels of control devices to achieve marginal
emissions reductions.

A monitoring consultant disagreed with the perception that CEMS cost too
much for facilities to use, stating that EPA?s requirements for daily
equipment calibration adds to the cost of CEMS. An EPA air program official
said that the agency?s data quality and daily calibration requirements
provide certainty of facility emissions, which he views as critical to the
integrity of emissions trading programs. The monitoring consultant estimated
that the average capital cost of a CEMS for facilities participating in the
Acid Rain program- including daily calibration- ranged between $150,000 and
$200,000, with annual operating costs of $50,000. Similarly, an industry
group estimated in 1998 that the total capital investment for a nitrogen
oxide CEMS similar to those used in a California emissions trading program
would range between $71,500 and $127,500, and that the total annual cost of
owning and operating the system would be approximately $24,000 to $38,000.

The consultant said that regulated facilities not participating in trading
programs could lower the costs of continuous monitoring if they had less
rigorous calibration requirements. He said, for example, that facilities in
Germany perform tests to determine how often the equipment needs
calibration, and then work with the regulatory agency to arrive at an
agreed- upon calibration schedule. In some cases, facilities only need to
calibrate their equipment monthly. The consultant suggested that
disseminating information on the true costs of CEMS would demonstrate that
they are not as expensive as believed, thereby making it easier for EPA to
require their use. For example, he stated that simple systems used in Canada
and Norway cost between $30,000 and $50, 000.

Thus, there may well be situations where the costs of CEMS are lower than
perceived, and in fact are lower than their potential benefits. There may
also be ways in which EPA itself could lower CEMS? costs by, for example,
adjusting its requirements for daily equipment calibration at

Chapter 2: Technologies for Measuring Emissions From Stationary Air Sources

Page 31 GAO- 01- 313 Environmental Protection

facilities that do not participate in trading programs. We believe such
situations can best be identified through systematic cost- benefit analysis.

While regulated facilities must adhere to EPA?s approved test methods and
performance specifications, EPA will conditionally approve alternative
methods that still meet the agency?s data requirements, and sometimes
receives and approves requests to use advanced monitoring technologies. For
example, in 2000, the agency approved a request to use a PEMS for compliance
monitoring at an industrial boiler.

Between June 1996 and November 2000, EPA received 115 requests to use
alternative methods. Of these, 54 were approved, 3 were denied, and 2 were
later withdrawn by the submitter. Approximately 83 percent of the approvals
were issued in less than six months. An EPA official said that the remaining
submittals were either (1) never listed in the agency?s database as an
approval or disapproval, (2) lacked additional information requested of the
submitter, or (3) were determined not to be an alternative test method or
monitoring request under federal regulations.

According to the president of a monitoring company, conditional approval
does not necessarily lead to the widespread acceptance of promising
technologies. He discussed the time, cost, and limited benefit associated
with conditional approval of alternative methods. He cited the example of a
technology that monitors volatile organic compounds and hazardous air
pollutants using gas chromatography and mass spectroscopy. The device, which
costs between $60,000 and $80,000 provides results about every ten minutes.
He said the manufacturer has spent millions of dollars developing the
technology and between $300,000 and $400,000 trying to get EPA approval. He
said that he could not get EPA to identify a testing protocol to demonstrate
the technology?s equivalency to the approved method, so his company designed
its own. EPA accepted the protocol, but was still hesitant to approve the
technology even after it met the testing requirements. After the
manufacturer contacted one of its Members of Congress, who in turn contacted
the EPA Administrator, EPA finally offered conditional approval. He
described this outcome as ?totally

unacceptable? because it required the manufacturer to request approval from
the relevant state agency or EPA each time a facility wants to use the
technology. He said that state agencies, which implement clean air
Conditional Approval of

Alternative Methods Can Foster Use of Advanced Technologies

Chapter 2: Technologies for Measuring Emissions From Stationary Air Sources

Page 32 GAO- 01- 313 Environmental Protection

programs, generally prefer for regulated entities to use methods that have
more widespread acceptance by EPA. 9

The presence or absence of regulatory requirements not only influences the
use of existing technologies, but also the research and development of new
technologies. An equipment manufacturer and regulators said that without
regulatory requirements, manufacturers have little incentive to bring new
technologies to market. As a result, more of the research and development
burden falls to government agencies, which generally can devote limited
resources to this purpose.

In 1995, EPA?s Science Advisory Board characterized the use of CEMS for
measuring air toxics as a problem of what must come first: the regulatory
mandate for CEMS that drives the market or commercially available CEMS that
allow regulators to mandate their use. The Board said that EPA must have the
confidence that a technology can fulfill the agency?s needs before it can
write a rule requiring its use. It also noted that instrument developers and
manufacturers were unlikely to conduct the expensive research and
development required to make technologies available unless EPA mandated
their use. The Board suggested that EPA try to break the deadlock and
recommended that EPA identify all of the barriers to the availability of
commercial, cost- effective CEMS and address them in a systematic manner.
Officials in EPA?s research and development office said that the development
and implementation of advanced emissions monitoring technologies has no
clear starting point. EPA?s Acid Rain program suggested that a cost- benefit
analysis would be a logical first step.

In a similar vein, equipment manufacturers and regulators told us that
regulatory requirements define the market for advanced monitoring
technologies, such as CEMS. An industry consultant said that equipment
developers seldom pursue new technologies unless they see the potential for
a regulation that would require monitoring. He noted that, a developer who
saw an opportunity would try to determine the size of the market and the
number of monitoring units that will be needed. It will then evaluate the
competition and try to estimate its potential share of the market. After

9 EPA?s Office of Air and Radiation said that the device does not satisfy
the data collection requirements necessary to obtain approval as an
alternative to an EPA test method. However, EPA also said that the device
collects data often enough to meet CEMS performance specifications, for
which no EPA approval would be necessary. Factors That

Influence Development of New Air Monitoring Technologies

Lack of Regulatory Requirements Discourages Development of New Technologies

Chapter 2: Technologies for Measuring Emissions From Stationary Air Sources

Page 33 GAO- 01- 313 Environmental Protection

evaluating this information, it will seek to determine the appropriate level
of investment the opportunity justifies. As an example, he said that several
companies which have recently developed particulate matter monitoring
technologies face significant financial risk if EPA delays or decides not to
impose monitoring requirements as part of its new particulate matter rules.

EPA officials said that technologies exist to monitor most of the pollutants
that are not monitored, and that additional monitoring of these pollutants
does not require ?leaps of science.? Similarly, a representative of an
equipment industry trade association stated that ?if regulations are
imposed, the technology will follow.? He also said that the trade
association had once asked its members for case study examples of their new
technologies and most had responded that they did not pursue new technology
without a potential or existing market. An equipment vendor said that most
improvements involve incremental changes that lower costs and enhance
performance.

The lack of incentives for private research and development leaves some of
the burden on government. According to agency officials, EPA devotes a
limited amount of funding to the development of advanced monitoring
technologies, but this focuses on supporting agency research objectives,
such as improving the scientific understanding of pollutants, rather than
bringing promising technologies to market. For example, we interviewed an
official in EPA?s Office of Research and Development who is pursuing a
technology that measures air toxics, such as dioxin. The official described
this technology as providing versatile measurement -- in terms of the range
of pollutants detected and the levels at which it detects them-- and as a
significant advance in monitoring technology, but it would take an
additional $5 million to make this technology commercially available. Given
EPA?s resource constraints, the funds would have to come from the private
sector. In fiscal year 2001, EPA devoted $247, 900 to the research and
development of point source air monitoring technologies, such as CEMS. The
official stated, however, that the lack of regulatory requirements and the
high cost of bringing technologies to market make the research and
development of this and other technologies a very risky venture for
equipment manufacturers.

According to EPA?s Office of Research and Development, the agency?s ETV
program can assist in overcoming the barriers to the introduction of new
monitoring technologies developed by the private sector. As of June 2000,
ETV had completed performance testing or verification of over 30 air EPA and
Other Federal

Agencies Perform Limited Research and Development

Chapter 2: Technologies for Measuring Emissions From Stationary Air Sources

Page 34 GAO- 01- 313 Environmental Protection

monitoring technologies, including mercury and multiple- metals CEMS,
particulate matter monitors, and portable nitrogen oxide analyzers.

Other federal agencies, including the Department of Energy (DOE) and
Department of Defense (DOD), also research and develop monitoring
technologies. DOE targets its efforts on the continuous monitoring of
pollutants, including mercury, arsenic, and lead, at contaminated DOE sites.
Through its Strategic Environmental Research and Development Program, DOD
develops improved monitoring tools for environmental compliance. For
example, DOD has developed a laser technology that allows near- real- time
in- stack analysis of a range of metal and gas pollutants. An EPA official
said, however, that the research and development performed by external
parties, such as DOD, does not always provide results that are acceptable
for regulatory purposes.

The compliance monitoring that stationary air pollution sources perform
varies considerably. As a result, regulators and regulated entities
sometimes lack certainty about whether air pollution sources maintain
continuous compliance with clean air regulations.

Advanced monitoring technologies, particularly CEMS, can provide facilities
with information that enables them to improve the efficiency of their
processes, thereby reducing emissions and providing cost savings. EPA
officials consider CEMS to provide the greatest certainty of a facility?s
emissions. In addition, EPA data show that use of advanced technologies
correlates with emissions reductions at regulated entities.

However, there are powerful disincentives to the voluntary use of
technologies. Among the greatest disincentives is EPA?s Credible Evidence
rule, which enables the use of data derived from use of advanced
technologies as the basis for enforcement actions. EPA has indicated that it
does not plan to use this rule in cases of minor violations identified
through the use of these technologies. Nonetheless, EPA air program
officials and others that we interviewed conveyed a widespread belief that
the rule continues to place emitters at risk for enforcement action. Largely
as a result of these concerns, emitters generally use advanced monitoring
technologies in circumstances in which they are required to do so by
regulations, such as the requirements for CEMS use at facilities
participating in the Acid Rain program.

An additional disincentive for the wider use of CEMS is the perception that
CEMS? costs are unacceptably high. However, EPA does not regularly
Conclusions

Chapter 2: Technologies for Measuring Emissions From Stationary Air Sources

Page 35 GAO- 01- 313 Environmental Protection

evaluate the costs and benefits of alternative compliance monitoring
options. Such an evaluation would involve analyzing data on (1) the costs of
purchasing and operating monitoring equipment, taking into consideration
different equipment calibration and performance requirements, and (2) the
benefits of using these technologies, such as their value in facilitating
emissions trading programs, as well as the ability to achieve increased
compliance and emissions reductions.

We recommend that the Administrator, EPA, direct the agency?s Office of Air
and Radiation, to develop a strategy that would address the barriers that
impede wider use of advanced monitoring technologies. As a part of this
strategy, EPA should:

 Identify ways to alleviate the widespread view among emitters that it will
use the Credible Evidence rule in enforcement cases where voluntary use of
such technologies may reveal minor violations.

 Undertake an analysis of the costs and benefits associated with different
compliance monitoring options in a manner that would help to identify
additional opportunities for the expanded use of advanced monitoring
technologies.

EPA?s Office of Air and Radiation provided comments on the material covered
in this chapter. The Office said that, overall, we accurately covered the
issues and reached fair conclusions. The comments provided were generally
editorial or intended to clarify the material presented, and we incorporated
them as appropriate. For example, we added text to clarify that EPA?s
approved methods and performance specifications for monitoring individual
pollutants do not apply to all types of regulated entities or industrial air
pollution sources.

EPA?s Office of Research and Development provided comments from several
individuals responsible for the development and validation of monitoring
technologies. These comments covered a wide range of issues, but generally
suggested that we (1) clarify our definition of ?advanced?

monitoring technologies, (2) more comprehensively discuss several issues
relating to the development of new monitoring technologies, and (3) enhance
our discussion of the role that the agency?s ETV program can play in
addressing barriers to the introduction of new monitoring technologies.
Recommendations

Agency Comments

Chapter 2: Technologies for Measuring Emissions From Stationary Air Sources

Page 36 GAO- 01- 313 Environmental Protection

Regarding (1), we clarified that our discussion of advanced monitoring
technologies focuses on those that can improve regulated entities? ability
to monitor their compliance with air regulations. Regarding (2), the Office
of Research and Development suggested that we more comprehensively discuss
the available monitoring technologies, the improvements that are necessary,
and the benefits of improved monitoring. We believe that it was limited in
the level of detail the report should devote to these matters by the
enormous range of technologies that address air monitoring and the need to
devote sufficient attention to the legal and regulatory barriers inhibiting
wider use and development of such technologies, which was the primary focus
of the report. Regarding (3), we expanded our discussion of ETV as it
relates to the development of performance specifications and test methods,
as well as to bridging the gap between commercial availability of
technologies and their use for regulatory purposes. We also made suggested
editorial changes where appropriate.

EPA?s Office of Enforcement and Compliance Assurance did not provide
comments on the material covered in this chapter.

Chapter 3: Technologies for Measuring Wastewater Discharges

Page 37 GAO- 01- 313 Environmental Protection

For decades, wastewater treatment plants and industrial facilities have been
required to monitor the concentrations of pollutants in their wastewater.
Consequently, technologies have been developed to measure hundreds of
pollutants of interest. Many of these technologies, however, are over 15
years old. A number of newer technologies can monitor pollutants in a manner
that is more cost- effective and/ or more accurate than those that are
currently in use. However, because EPA has not approved these technologies
for monitoring compliance with wastewater discharge permits, they are not
widely used for this purpose.

EPA is quick to approve requests to use alternative methods intended for use
by a single entity, and has significantly expedited its response time in
reviewing minor modifications to existing methods. However, a lengthy and
cumbersome approval process has served as a major disincentive to equipment
manufacturers seeking to develop innovative monitoring technologies with
nationwide application. EPA has tried to address the problem through a
streamlined ?performance- based? approval process, but the agency has not
implemented this process because it has not resolved all the issues impeding
its use.

As noted in chapter 1, a Clean Water Act program requires regulated
facilities to monitor their wastewater discharges to ensure their compliance
with pollutant discharge limits. Currently, there are about 96,000
facilities that are regulated under the act?s pollutant discharge program.
Of these, about 6, 600 discharge in quantities sufficient enough to be
deemed ?major? dischargers. These facilities include (1) sewage treatment
facilities with a design discharge daily flow greater than one million
gallons of effluent- a mix of domestic and industrial wastewater, (2)
certain classes of industrial facilities, and (3) industrial facilities that
discharge a certain amount or concentration of pollutants. In general, major
dischargers may be required to report the quantity and content of their
discharge to EPA or a state regulatory agency on a monthly basis, although
they may monitor their effluent on a daily or more frequent basis. Other
dischargers may monitor and report on a less frequent basis. Table 3
identifies the industrial facilities that discharge the greatest quantity of
conventional and toxic pollutants. 1

1 Conventional pollutants include those typically found in municipal sewage,
such as fecal coliform bacteria, oil and grease, and pH. Toxic pollutants
include metals and manmade organic compounds. Chapter 3: Technologies for
Measuring

Wastewater Discharges Monitoring Wastewater Discharges Under the Clean Water
Act

Chapter 3: Technologies for Measuring Wastewater Discharges

Page 38 GAO- 01- 313 Environmental Protection

Table 3: Industrial Sources of Conventional and Toxic Pollutants Source
Category Quantity of Discharges

(in tons) Proportion of Total (percentage)

Coal Mining 1,069,764, 866 85 Primary Metal Industries 128,853,898 10
Electric, Gas, and Sanitary Services 39,448,827 3 Other* 21,190,169 2

Total 1,259,257, 760 100

Note: Other includes more than 70 individual source categories. Source: EPA

While the monitored pollutants and the frequency of the monitoring may vary
among regulated facilities, regulated entities must use EPA- approved test
methods. Test methods describe the analytical procedures for measuring the
presence and concentration of pollutants. In promulgating guidelines for its
test methods, EPA has issued regulations that reference specific test
methods and, in some cases, the actual text of a test method.

Since the 1970s, EPA and consensus standards organizations, such as the
American Society for Testing and Materials, have developed most of the
currently approved 710 test methods for the monitoring of over 400
pollutants. 2 (Examples of test method categories are summarized in table
4.) In addition, EPA allows the regulated community, instrument
manufacturers, and other entities to apply for agency permission to use an
alternative test method in the place of an EPA- approved method. According
to EPA, these alternative test methods are either modifications to approved
test methods or new test methods. Applicants seek approval for an
alternative test procedure when the alternative procedure improves some
aspect of method performance, such as reducing analytical costs, improving
laboratory productivity, or reducing the amount of hazardous materials used
in the laboratory.

2 Consensus standards organizations include groups such as the American
Society for Testing and Materials and the publishers of Standard Methods for
the Examination of Water and Wastewater. These organizations develop
voluntary consensus standards for monitoring through the participation of
all interested stakeholders, including producers, users, consumers, and
representatives of government and academia.

Chapter 3: Technologies for Measuring Wastewater Discharges

Page 39 GAO- 01- 313 Environmental Protection

Table 4: Examples of EPA Test Method Categories Test Method Category
Pollutant Measured Technology/ Instrument Used

Bacteria (fecal coliform) Human observation of bacteria present Biological
methods Aquatic toxicity Human observation of fish

mortality rates Oil and grease Hexane extraction and

gravimetry Nitrate Colorimetric Inorganic methods

Metals Graphite furnace atomic absorption PCBs Gas chromatograph/ mass

spectrometer Non- pesticide organic methods

Dioxin Gas chromatograph/ mass spectrometer Pesticide methods Pesticides (e.
g., DDT) Gas chromatograph/ mass

spectrometer Source: Title 40, Code of Federal Regulations, Part 136

According to EPA, improvements in instrumentation, the quality of test
methods, and the number of laboratories capable of performing analyses for
environmental monitoring have grown substantially since the 1970s. However,
according to officials with EPA and other organizations that we interviewed,
while many methods exist to measure pollutants in wastewater, approximately
one- third of EPA- approved methods are over 15 years old.

In a 1988 report to the Congress on the availability of monitoring
technologies and methods, EPA cited several examples of new technologies
that could exceed the performance of existing methods in terms of better
sensitivity, lower cost, and more reliable identification of regulated
pollutants. 3 For monitoring inorganic pollutants, EPA cited two
technologies- inductively coupled plasma/ mass spectrometry (ICP/ MS) and
ion chromatography- that could (1) decrease the cost of analyses, (2)
increase laboratory productivity and the quality of the analytical data, and
(3) lower the effective detection limits in a wide variety of samples. Other
experts we interviewed, including representatives of consensus

3 Availability, Adequacy, and Comparability of Testing Procedures for the
Analysis of Pollutants Established Under Section 304( h) of the Federal
Water Pollution Control Act,

Report to Congress, Office of Research and Development, EPA (EPA/ 600/ 9-
87/ 030. Sept. 1988). Available

Technologies That Can Improve Wastewater Monitoring

Chapter 3: Technologies for Measuring Wastewater Discharges

Page 40 GAO- 01- 313 Environmental Protection

standards boards, state regulatory agencies, regulated entities, and
commercial laboratories, also cited these two technologies as among the most
significant improved technologies available.

Inductively coupled plasma/ mass spectrometry (ICP/ MS) is used to measure
inorganic elements (e. g., metals) and provides significant improvements
over currently approved technologies in terms of lower detection levels and
reduced cost per sample. The ICP/ MS first became commercially available in
the early 1980s and has been continuously improved, according to one
manufacturer we interviewed. A 1988 EPA report recognized the potential
improvement offered by ICP/ MS, stating that ?in the next decade, the
application of inductively coupled plasma/ mass spectrometry to
environmental analyses could result in the single greatest impact on the
analysis of metals.? An ICP/ MS instrument currently costs between $150,000
and $200,000, according to one manufacturer we interviewed.

An ICP/ MS can detect the concentrations of pollutants down to the parts per
trillion range, while a comparable technology approved by EPA (i. e., a
graphite furnace) can only detect down to parts per billion. Measuring to
such levels is important when regulated entities are discharging to waters
that are impaired by certain pollutants. For example, in cases where certain
waters are impaired by mercury or lead, the regulated entities discharging
to these waters must reduce their discharges of these pollutants to very low
levels (i. e., lower than what is normally required). In its 1988 report,
EPA specifically recommended that efforts to develop ICP/ MS test methods
consider monitoring toxic metals at low concentration levels.

An additional key benefit of the ICP/ MS is that it can rapidly analyze
multiple elements in a single sample, as opposed to many current EPA-
approved test methods, which use technologies that analyze only one element
at a time. Accordingly, the ICP/ MS can reduce costs to users such as
commercial laboratories or large sewage treatment plants that test numerous
samples. Representatives of one wastewater treatment plant told us that
using the ICP/ MS could reduce their analysis costs by about 20 percent
below the cost of current EPA- approved methods.

Ion chromatography is used to measure inorganic substances, such as nitrates
and phosphates. Like the ICP/ MS, it can reduce costs incurred by facilities
that must process and analyze numerous samples. Furthermore, Inductively
Coupled

Plasma/ Mass Spectrometry Ion Chromatography

Chapter 3: Technologies for Measuring Wastewater Discharges

Page 41 GAO- 01- 313 Environmental Protection

EPA recognized ion chromatography?s potential in its 1988 Report to
Congress, calling it an important technology that would become more
routinely used for monitoring pollutants in the future. This technology was
first commercially available in the mid- 1970s and currently costs between
$14,000 and $60,000, according to one manufacturer we interviewed.

The major benefit of ion chromatography is that it can rapidly analyze
multiple pollutants in a single sample, as opposed to current EPA- approved
methods for wastewater monitoring that analyze one pollutant at a time. As a
result, ion chromatography can reduce costs to users, such as commercial
laboratories or large sewage treatment plants that test numerous samples. In
addition, ion chromatography can detect levels of pollutants in the parts-
per- billion range, which is considerably more sensitive than current EPA-
approved test methods for wastewater.

Representatives of the commercial laboratories we interviewed said that they
routinely use ICP/ MS and ion chromatography to monitor pollutants regulated
under the Safe Drinking Water Act (these technologies are approved for use
in this program). However, according to EPA officials, the majority of
regulated entities do not use these technologies for compliance monitoring
under the Clean Water Act because EPA has yet to formally approve them for
that purpose. Since regulated entities may only use an approved monitoring
method, a facility could be found in noncompliance if it uses an unapproved
technology or method.

EPA proposed approving the use of ICP/ MS and ion chromatography for
wastewater compliance monitoring in the mid- 1990s. However, agency
officials noted that funding constraints prevented them from performing
additional validation studies, which were needed to demonstrate the
reliability of the ICP/ MS method for use in wastewater monitoring
(additional studies were not needed for the ion chromatography method, but
EPA is waiting to promulgate these methods as a single rule). They pointed
in particular to the over 50 percent decline in funding devoted to method
development and validation over the past 4 fiscal years (see fig. 4).
According to these officials, this area lost much of its funding when
resources were shifted to other priority activities, such as the development
of effluent limitations and guidelines with court- ordered deadlines.
Because of these delays, EPA?s Office of Water has authorized regional
offices, upon request, to give approval to any facility that requests to use
either the ion chromatograph or ICP/ MS method. To date, four regional
offices have requested this authority. Extent to Which

Improved Wastewater Monitoring Technologies Are Being Used

Chapter 3: Technologies for Measuring Wastewater Discharges

Page 42 GAO- 01- 313 Environmental Protection

Figure 4: EPA?s Office of Water Method Development Budget for Wastewater
Monitoring

Note: In constant dollars, base year 2000. Source: EPA

EPA is quick to approve methods intended for use by a single entity, and has
significantly expedited its response time in reviewing minor modifications
to existing methods. EPA?s recent changes to streamline its approval process
were viewed very favorably by two instrument manufacturers who had recently
been through the process. However, EPA?s review process for major
modifications or new methods developed by outside organizations for
nationwide use remains time- consuming and discourages some manufacturers
from pursuing innovations for wastewater monitoring. EPA has acknowledged
the problem and proposed a ?performance- based? approval process, but has
not implemented this process due to unresolved issues within the agency.

Until the mid- 1990s, EPA usually initiated work on all new test methods
used in monitoring wastewater compliance. EPA maintained a program for
organizations outside the agency to apply for the approval of major or minor
modifications to existing EPA methods. However, EPA officials associated
with the program, and organizations that went through its Factors That

Influence Development of Improved Wastewater Monitoring Technologies

EPA?s Approval Process for New or Modified Test Methods

Chapter 3: Technologies for Measuring Wastewater Discharges

Page 43 GAO- 01- 313 Environmental Protection

process, described it as lengthy and hard to use. Furthermore, EPA
recognized in 1996 that the requirement to use prescriptive test methods and
technologies had unintentionally imposed a significant regulatory burden and
created a barrier to the use of innovative environmental monitoring
technology.

To encourage the development of new and innovative technologies by outside
organizations, and to expedite approval of major or minor modifications to
existing EPA methods, EPA revamped its process for approving methods
developed by outside organizations for wastewater compliance monitoring.
EPA?s process requires varying levels of validation, review, and approval of
proposed methods, depending on the method?s intended use (use by only the
applicant as opposed to use by any monitoring entity). 4 The organization
submitting a proposed method is responsible for conducting the necessary
validation studies. EPA reviews the results of these studies to determine
the applicability and performance of a proposed method before making an
approval decision. In general, the process requires organizations to perform
more testing if they are proposing more significant changes and/ or a method
for nationwide use, rather than simply for use by an individual facility.
Table 5 highlights the varying levels of validation and approval required
for different types of proposed methods.

4 The most recent guidelines are found in Protocol for EPA Approval of
Alternate Test Procedures for Organic and Inorganic Analytes in Wastewater
and Drinking Water

(March 1998) and Protocol for EPA Approval of New Methods for Organic and
Inorganic Analytes in Wastewater and Drinking Water (March 1999).

Chapter 3: Technologies for Measuring Wastewater Discharges

Page 44 GAO- 01- 313 Environmental Protection

Table 5: Validation and Approval of Proposed Methods Type of Proposed Method
Intended Users Level of Validation

Required Type of Approval Minor Modifications

(for very minor modifications to EPA approved methods)

Applicant only or anyone Little or no formal

validation Approval by EPA Headquarters

through approval letter

Limited Use

(for both major modifications to EPA approved methods and for new methods)

Applicant only 1 lab validation study Approval by EPA Regional Office
through approval letter (may consult with EPA Headquarters)

Nationwide Use

(for both major modifications to EPA approved methods and for new methods)

Anyone 3 to 9 lab validation study Approval by EPA

Headquarters through formal rulemaking

Source: GAO analysis of EPA?s process

Minor Modifications. While proposals for minor modifications are not likely
to result in major improvements for users, commercial laboratories and
equipment manufacturers depend on EPA approval. According to one EPA
official, older EPA approved methods are very specific. They may prescribe,
for example, the size of glassware (e. g., a 100- milliliter beaker) that
must be used when performing the test method. This official noted that in
some instances, state compliance officials have questioned minor deviations
that commercial laboratories have made from these methods. As a result,
laboratories have had to submit applications to EPA seeking approval for
very minor modifications. In addition, as one equipment manufacturer noted,
potential buyers are reluctant to use any monitoring methods for compliance
purposes that have not been certified by EPA out of fear that they may be
found in noncompliance with their wastewater monitoring requirements.

Limited Use. Unlike applications for minor modifications, proposals for
limited use applications- those for use by a single entity- are for
significant changes to existing EPA- approved test methods or entirely new
methods. According to EPA, the ?limited use? distinction is used primarily
by regulated facilities, commercial laboratories, or other entities that
routinely monitor samples from the same site or sites. However, EPA only
allows the facility or laboratory that applies for a limited- use approval
to

Chapter 3: Technologies for Measuring Wastewater Discharges

Page 45 GAO- 01- 313 Environmental Protection

use the test method. Consequently, EPA does not require these applicants to
perform extensive validation studies involving multiple laboratories.

Nationwide Use. In contrast to applications proposing minor modifications or
changes for which use is limited to a single facility, proposals for new
methods or major modifications intended for nationwide use have a greater
potential to affect the entire regulated community because these methods, if
approved, will be available for nationwide use. Consequently, EPA requires
nationwide- use applications to undergo a validation study in which the
performance of the proposed method is verified by three to nine independent
laboratories. If necessary, EPA may ask applicants to revise their proposed
methods before deciding that a method is acceptable.

In addition to the technical review- the process by which EPA examines an
application and determines the applicability and performance of a proposed
method- EPA requires all new methods or major modifications intended for
nationwide use to go through the rulemaking process. During the rulemaking
process, a method is published as a proposed rule in the

Federal Register, public comments are received and addressed, and the method
is published as a final rule.

Our analysis of EPA data for applications for minor modifications- including
40 applications submitted between fiscal years 1993 and 2000- shows that EPA
took an average of about 1.4 years to review and issue a decision. However,
the timeliness of EPA?s responses has improved significantly in recent
years. For example, agency data show that it took an average of 4.5 months
to reach a decision on applications received during fiscal year 1999, the
last year for which complete data are available. Two equipment manufacturers
that recently went through EPA?s approval process substantiated the process?
expedited response time. They noted that, as a result of the changes made to
the approval process by the agency, EPA?s performance improved substantially
during the past few years.

EPA data show that the agency?s quickest response time came when reviewing
and issuing an approval decision for limited- use applications. Our analysis
of EPA data for 26 limited- use applications submitted between fiscal years
1993 and 2000 shows that EPA took an average of about 4 months to review the
applications (including reviewing the results of the required single- lab
validation study) and to issue a decision. EPA Has Streamlined Its

Process for Approving Minor Modifications

Chapter 3: Technologies for Measuring Wastewater Discharges

Page 46 GAO- 01- 313 Environmental Protection

While EPA has received considerable praise for its improved performance in
processing proposals for minor modifications, this improvement may be short-
lived, according to both the agency officials and potential applicants we
interviewed. In fiscal years 1999 and 2000, EPA supplemented its own staff
resources with an allocation of $75,000 per year for a contractor to perform
reviews and assist in administrative duties. However, in fiscal year 2001,
no such funds have been provided because all available contract dollars are
being used to fund programs that directly support court- ordered deadlines
and schedules. Instead, the agency is performing all work with internal
resources equivalent to one full- time staff person. EPA officials
acknowledge that this funding cut will slow the approval process down, and
two equipment manufacturers we interviewed expressed concern that the
program may cease to function altogether.

While EPA has improved its process for approving minor modifications, its
approval process for the most promising methods- those involving major
modifications or new monitoring methods with nationwide application-
continues to be time- consuming. Our analysis of EPA data on nationwide use
applications shows that between fiscal years 1993 and 2000, EPA approved two
nationwide use methods out of the total 101 applications it received. 5 It
took about three years for one of the approved methods to go through both
the EPA technical review process and the formal rulemaking process, while
the other method took about 3.6 years. 6 In a third case that is currently
going through the rulemaking process, the sponsor projects that it will take
a total of 5 years before the method would be approved and published as a
final rule. A wide variety of the organizations that we interviewed,
including state regulatory authorities, regulated entities, and equipment
manufacturers, expressed concern over EPA?s lengthy approval and rulemaking
process.

The National Water Quality Monitoring Council, a federal advisory committee,
has voiced similar concerns about EPA?s approval process. In a 1999 position
paper on environmental monitoring, the Council stated

5 Of the other 99 applications received for nationwide use, 8 were
disapproved, 3 were cancelled by the applicant, 16 were closed by EPA, 2
were not sent to the proper state or EPA Regional authority, 42 are awaiting
additional data from the applicant, 26 are still under review by EPA, and 2
are awaiting rulemaking.

6 The length of time to obtain EPA approval cannot be solely attributed to
EPA?s technical review or the rulemaking process. For example, 42
applications are awaiting action by the applicant. Nationwide- Use Methods

Are Hindered by Lengthy EPA Approval Process

Chapter 3: Technologies for Measuring Wastewater Discharges

Page 47 GAO- 01- 313 Environmental Protection

that, ?Due to current bureaucratic and administrative constraints, it is
time consuming, resource intensive, and cumbersome to modify existing
methods or add new improved methods to the Federal Register. The result is
that more sensitive, less expensive, faster, or more modern methods-
developed either by federal agencies or consensus organizations- have not
been easily implemented or encouraged in compliance or ambient monitoring.?
7

According to the EPA officials that we interviewed, the requirements of the
rulemaking process prolong the agency?s timeframes for approving nationwide-
use methods. EPA officials estimated that the rulemaking process- which
includes proposing a rule in the Federal Register, receiving and responding
to comments on the proposed method, sending the final rule through EPA?s
internal review process (which includes a review by the Office of General
Counsel), and publishing the final rule- can take from 1 to 3 years. Another
factor contributing to the length of the process is EPA?s shift of resources
away from the development and approval of innovative test methods to other
priority activities, such as development of effluent limitations and
guidelines with court- ordered deadlines. As noted previously, EPA funding
to support the approval process for methods developed by outside
organizations was eliminated in fiscal year 2001.

Competing priorities within the EPA Office of Water are not the only
problem. Other EPA offices also have to prioritize their work, which can
slow down the approval of test methods. For example, an EPA official told us
that higher priorities in the Office of General Counsel have left an ICP/ MS
method waiting 6 months for review- an essential step before it can be
issued as a final rule.

In light of these difficulties, several equipment manufacturers who have
been through EPA?s approval process, told us that EPA?s lengthy approval
process has dissuaded them from pursuing both EPA approval of new wastewater
monitoring methods and significant modifications to existing ones. For
example, one equipment manufacturer told us that his company may only have a
limited time to recoup its investments in patented technologies once they
are finally approved for use. This manufacturer pointed out that, by the
time EPA approves its technology for nationwide

7 Methods & Data Comparability Board, National Water Quality Monitoring
Council, position paper on a Performance- Based Measurement System.

Chapter 3: Technologies for Measuring Wastewater Discharges

Page 48 GAO- 01- 313 Environmental Protection

use, his company will only have 4 years left on its 17- year patent to
exclusively manufacture its technology.

Two manufacturers spoke of opportunities to introduce innovative monitoring
technologies that had been frustrated by the approval process. One noted
that his company had invested in the development of ?clean?

monitoring methods that, unlike many current approved methods, do not
require the use of toxic materials in analyzing samples. Another cited a
monitoring technology that is already approved for drinking water
monitoring. In each case, however, the sponsors said that the lengthy
approval process deterred them from seeking EPA approval. These
manufacturers also told us that they have chosen to pursue the sales of
their monitoring technologies in other markets. For example, one
manufacturer told us that she prefers to sell her equipment in the more
profitable pharmaceutical market. Another manufacturer told us that he
prefers to invest in developing new methods for the biotechnology or
pharmaceutical monitoring market rather than the environmental market.

In addition, two of the equipment manufacturers that we interviewed said
that they are also focusing more of their attention on overseas markets.
This tendency is consistent with the findings in the 1998 U. S. Department
of Commerce report, which observed that ?U. S. environmental instrument
manufacturers have generated over half of their revenues from outside the
United States since 1994.?

Since the mid- 1990s, EPA has recognized the need to streamline its approval
process to decrease the amount of time and agency resources required to
approve new and modified test methods. According to EPA,

?Because advances in analytical technology continue to outpace the capacity
of [the Office of Water?s] method approval program, the program has been
under- utilized and slow to respond to emerging technologies.? 8 EPA made
changes to streamline its process in 1995, which improved its response time
in approving minor modifications to existing methods, but the approval of
major modifications and new methods for nationwide use still remains
problematic. EPA proposed a plan in 1997 to implement a performance- based
system for environmental monitoring in all of its programs, to the extent
feasible, which would address some of these

8 Protocol for EPA Approval of New Methods for Organic and Inorganic
Analytes in Wastewater and Drinking Water (March 1999). EPA Recognizes the

Problem but Has Yet to Implement a Solution

Chapter 3: Technologies for Measuring Wastewater Discharges

Page 49 GAO- 01- 313 Environmental Protection

continuing problems. 9 Such a system would convey ?what? needs to be
accomplished (i. e., what information a test method should yield), but not
prescriptively convey ?how? to do it.

To implement such a system, EPA stated that it would specify what questions
the measurement must answer, what decisions the resulting data are to
support, what level of uncertainty is acceptable for making the decisions,
and what documentation is required. EPA would specify performance criteria
for the measurements, and data producers would be required to demonstrate
that their proposed test method meets these criteria. 10 According to EPA,
such a performance- based approach would provide the regulated community
more flexible and less costly approaches to conducting required monitoring,
and importantly, would expedite the use of new and innovative technologies.

A large number of the organizations we interviewed- including
representatives from equipment manufacturers, state regulatory agencies,
regulated entities, commercial laboratories, and consensus standard
organizations- said that EPA should adopt a performance- based approach to
environmental monitoring. According to one equipment manufacturer, a change
to a performance- based approach would be the single most important thing
that EPA could do to improve its approval process. However, many of these
organizations also said that EPA might have problems implementing such a
system.

This concern was echoed in our discussion with EPA enforcement officials.
Officials within EPA?s Office of Enforcement and Compliance Assurance told
us that under a performance- based system, regulated facilities would be
able to use new or modified test methods without having to obtain an
official review by EPA officials with the requisite technical skills. They
claimed that a performance- based system places extra demands on federal and
state inspectors to determine whether alternative monitoring methods are
technically acceptable. They also told us that a performance- based system
would make it harder to litigate cases

9 EPA notice in Federal Register, vol. 62, no. 193, Oct. 6, 1997. EPA
defines a performancebased measurement system as a set of processes wherein
the data quality needs, mandates, or limitations of a program or project are
specified, and serve as criteria for selecting appropriate methods to meet
those needs in a cost- effective manner.

10 According to EPA, performance characteristics can include parameters such
as detection limits, precision, accuracy, analysis time, and analysis cost.

Chapter 3: Technologies for Measuring Wastewater Discharges

Page 50 GAO- 01- 313 Environmental Protection

against facilities, since the validity of new or alternative methods would
have to be established in court.

According to officials in EPA?s Office of Water, the performance- based
approach in approving wastewater- monitoring technologies remains
unimplemented largely due to concerns of the enforcement office. They told
us that they held discussions with enforcement officials last year to try to
address their concerns. However, they stated that since the two offices have
not been able to reach a consensus on how to implement the program, EPA?s
Office of Water has postponed taking further actions.

Technologies exist that can monitor many of the pollutants of interest found
in wastewater discharges from sewage treatment plants and industrial
facilities. While incremental improvements to these technologies continue to
be made, more significant advances have been less frequent. EPA?s lengthy
approval process has dissuaded instrument manufacturers from pursuing major
innovations. Because instrument manufacturers are reluctant to pursue major
modifications or the development of new methods, regulated entities may be
missing opportunities to use significantly improved technologies that can
improve the accuracy of monitoring or lower its cost.

EPA has taken steps to mitigate this problem by improving its approval
processes. The agency successfully streamlined its approval of methods that
are minor modifications to existing ones. However, in fiscal year 2001, the
agency eliminated the $75,000 in contractor funding that had supported its
process improvements. Such reductions threaten to reverse the gains that
have been achieved.

The approval of major modifications or new methods is particularly
problematic. The proposed use of a performance- based measurement system by
EPA?s Office of Water offers a promising alternative to the review and
rulemaking process, although there are implementation issues that still must
be resolved. If EPA wants to promote and embrace innovative use of
wastewater monitoring technology, the agency needs to resolve these issues
before implementing such a system.

To ensure that the applications for minor modifications or limited use
methods continue to receive timely review, we recommend that the
Administrator, EPA, direct the Office of Water to track the results of its
Conclusions

Recommendations

Chapter 3: Technologies for Measuring Wastewater Discharges

Page 51 GAO- 01- 313 Environmental Protection

review and approval of these applications over the course of the coming
year. The Office should compare these results to those of recent years to
determine the impact of fiscal year 2001 funding reductions on the
timeliness of its reviews. If the agency determines that funding reductions
have had a significantly negative impact, it should consider restoring the
funding or taking other measures to compensate for the loss of such funding.

To encourage the development of new or significantly improved test methods
for use in wastewater monitoring, we recommend that the Administrator, EPA,
direct the Office of Water and the Office of Enforcement and Compliance
Assurance to work together to resolve remaining differences over the use of
a performance- based measurement system in wastewater monitoring, and to
move forward with implementation of the agreed- upon system.

EPA?s Offices of Water and of Enforcement and Compliance Assurance did not
provide comments on the material covered in this chapter. The agency?s
Office of Research and Development provided several comments, which largely
involved technical suggestions and clarifications. For example, one official
suggested we clarify that while technologies have been developed to measure
most classes of pollutants in wastewater, practical detection techniques do
not yet exist for some important

individual pollutants. We made revisions in response to this and other
comments as appropriate. Agency Comments

Chapter 4: Technologies for Measuring Emissions From Nonpoint Water Sources

Page 52 GAO- 01- 313 Environmental Protection

Measuring pollutant discharges from nonpoint sources is very different than
measuring discharges from wastewater sources or emissions from stationary
air sources. Because of the diffused nature of nonpoint sources, direct
monitoring of pollutant contributions is exceedingly difficult and resource
intensive. Consequently, the measurement of nonpoint discharges typically
involves an analysis of various sources of data, such as those on water
quality conditions and land use practices, to estimate potential pollutant
contributions. We identified numerous technologies that can aid in these
estimates by obtaining more detailed data and increasing analytical
capability.

While most nonpoint source assessments are conducted by states, research-
oriented organizations, such as universities and the U. S. Geological Survey
(USGS), are more likely to use advanced technologies in water quality
investigations. Lack of funding, expertise, and time limit the more
widespread use of advanced technologies and techniques. In addition, there
is no central repository for information on the development and application
of new technologies and techniques useful in nonpoint source monitoring and
assessment. As a result, users may be missing opportunities to capitalize on
lessons learned and to avoid duplication of effort.

The diffused nature of nonpoint sources makes the direct measurement of
their individual pollutant discharges exceedingly difficult. However, the
importance of assessing pollutant contributions from nonpoint sources has
increased rapidly in recent years, given the intense pressure on the states
and EPA to develop pollutant reduction strategies for waters that do not
meet water quality standards. (These pollutant reduction strategies are
called ?Total Maximum Daily Loads,? or TMDLs.) While there is no estimate
for the number of nonpoint sources affecting these waters given their
numerous and diffused nature, states reported in 1998 that almost 300,000
miles of rivers and streams and about 8 million acres of lakes were not
meeting water quality standards; nonpoint sources are cited as contributors
to most of these polluted waters. 1

In a watershed with multiple sources of water pollution, it is often
difficult to determine the amount of a pollutant any given source has
contributed. For example, agriculture, pet waste, and homeowner lawn

1 These figures apply only to the minority of U. S. waters that have been
assessed. For example, 840,000 of the 3.6 million total miles of streams
have been assessed. Chapter 4: Technologies for Measuring

Emissions From Nonpoint Water Sources Monitoring and Assessing Nonpoint
Sources of Water Pollution

Chapter 4: Technologies for Measuring Emissions From Nonpoint Water Sources

Page 53 GAO- 01- 313 Environmental Protection

maintenance can all contribute nutrients (nitrogen and phosphorus) to nearby
waters, but most monitoring reveals only the level of nutrients present and
cannot identify the sources that contributed the nutrients or the amounts
they contributed. As a result, measuring nonpoint source pollution often
requires an analysis not only of water quality conditions, but also of (1)
the activities occurring on the land that could be potential contributors of
pollution and (2) the factors that influence the transport of pollution to
waters. Figure 5 illustrates the diffuse nature of nonpoint sources of
pollution as compared to point sources.

Chapter 4: Technologies for Measuring Emissions From Nonpoint Water Sources

Page 54 GAO- 01- 313 Environmental Protection

Figure 5: Nonpoint and Point Source Water Pollution

Chapter 4: Technologies for Measuring Emissions From Nonpoint Water Sources

Page 55 GAO- 01- 313 Environmental Protection

The assessment of pollutant contributions from nonpoint sources relies on
many data types. In addition to monitoring data on water quality conditions,
information on land use/ land cover (the vegetation or suburban/ urban
development present), soil type, climate, and topography all help to
identify potential pollutant sources and to explain pollutant transport
dynamics (how quickly pollutants travel from their source to receiving
waters). Given the complex relationships among these various factors,
mathematical models are often used to translate these data into probable
pollutant contributions from individual sources or groups of similar types
of sources.

The Clean Water Act directs states to develop programs that address nonpoint
source pollution but it provides no direction for the establishment of
minimum national controls or monitoring that must be implemented, such as it
does for the control of wastewater dischargers. As a result, there is no
formal approval process for identifying acceptable monitoring methods or
techniques, such as the approval processes used in the stationary air or
wastewater programs. While states bear the responsibility under the Clean
Water Act for dealing with nonpoint source pollution, numerous federal,
state, local, and other organizations monitor water quality conditions and
generate other types of data used in nonpoint source analyses.

Pollutant contributions from nonpoint sources are diffused, numerous, and
difficult to quantify. Traditional water quality monitoring techniques, such
as in- person sampling, are too resource intensive to monitor all the areas
needed. In addition, the availability of an increasing amount of related (or
ancillary) data requires the use of analytical tools to process them. There
are several areas where improved technologies can assist in (1) the sampling
and analysis of water quality and (2) the integration and analysis of
multiple sources of related information.

There are several improved technologies or methods for taking and analyzing
a water sample. While advances in laboratory- based measurements, such as
those discussed in chapter 3, will benefit nonpoint source analysis, the
users that we interviewed said that, in general, the greatest benefits come
from field- based monitoring and analysis devices.

Sampling Methods: Much of the data on water quality conditions that are
needed to assess nonpoint source pollution is collected manually- a person
physically collects water samples from a body of water. Such a Available

Technologies That Can Improve Monitoring and Assessment

Water Quality Sampling and Analysis

Chapter 4: Technologies for Measuring Emissions From Nonpoint Water Sources

Page 56 GAO- 01- 313 Environmental Protection

process is costly and time- consuming because staff must travel to the
location, follow certain protocols for collecting samples, and transport the
samples to a laboratory for analysis. In- person sampling can also sometimes
be hazardous because most nonpoint source pollution occurs during high flow
events, such as storms. Figure 6 shows several in- person sampling methods.
In certain situations, however, automatic sampling devices can be used.
These devices, which are triggered remotely by a user or by the high flow
event itself, collect water samples and store them for later transport to a
laboratory. While a person must still travel to the sampling location, the
device can take numerous samples over a period of many days or weeks. This
type of ?remote sampling? provides significant improvements over manual
collection in terms of the number of areas that can be sampled during a high
flow event, the frequency of sampling, and safety.

Chapter 4: Technologies for Measuring Emissions From Nonpoint Water Sources

Page 57 GAO- 01- 313 Environmental Protection

Figure 6: Examples of In- person Water Sampling Methods

Source: U. S. Department of Agriculture and U. S. Geological Survey

Field- based Analytical Methods: Some monitoring technologies allow users to
measure various water quality parameters in the field. Obtaining pollutant
measurements in the field is helpful in (1) reducing monitoring costs by
eliminating certain laboratory analysis, (2) providing real- time

Chapter 4: Technologies for Measuring Emissions From Nonpoint Water Sources

Page 58 GAO- 01- 313 Environmental Protection

results, and (3) enabling more efficient monitoring by facilitating
decisions about data adequacy and determining whether additional
measurements need to be taken- such a course of action is impossible when
waiting for a result from a lab analysis. Field- based technologies either
provide results instantaneously for manual recording, store results on disk
within the instrument for later downloading, or communicate results remotely
via telemetry, cellular phone, or satellite communications. In addition,
some of the field- based technologies can be left alone to analyze pollutant
levels continuously or at set intervals. This is particularly beneficial in
measuring pollutants like dissolved oxygen or nutrients, the concentrations
of which may vary throughout the day depending on temperature changes or
flow levels. Field- based ?sensors? are considered reliable for several
common water quality measurements of interest, such as temperature,
dissolved oxygen, and conductivity. Field- based ?analyzers? are generally
more sensitive than sensors and measure pollutants that are more complicated
to quantify, such as nitrates, although their reliability at low levels is
not yet well defined. 2

Pathogen Source Detection: Methods exist that use DNA analysis to identify
the source species of fecal- related bacteria in water. For example, a
project in Arizona used this technique to determine what percentage of fecal
coliform came from human, pet, and wildlife sources in a stream used heavily
for recreation. Preliminary results of the analysis indicated that the
initial perceptions about the source that contributed the most bacteria were
not correct. Similarly, studies in Virginia and Washington revealed
surprising findings that animals were the primary source of fecalrelated
bacteria in certain waters, not leaking sewers or septic systems as
researchers had originally suspected. Identifying sources of pollution in
cases like these is critically important to devising effective pollution
reduction strategies when the largest sources may not be obvious or easily
controlled.

While there are advances in taking water samples and conducting analyses or
measurements of pollutants, most of the individuals that we interviewed also
recognized the improvements in integrating and analyzing multiple types of
data as essential elements in nonpoint source assessment. Understanding
pollutant dynamics requires information about

2 Analyzers can take more precise measurements than sensors but can also be
significantly more expensive and difficult to maintain. Information
Integration

and Analysis

Chapter 4: Technologies for Measuring Emissions From Nonpoint Water Sources

Page 59 GAO- 01- 313 Environmental Protection

a multitude of diverse but interrelated elements, such as hydrology, soil
type, climate, and land use/ land cover. Obtaining information in all these
areas is resource- intensive and challenging. Without computers and other
analytical tools to assist in the management of this information, the
organization and interpretation of these disparate data would be resource
prohibitive.

Remote Sensing: Remote sensing technologies, such as satellite imagery and
aerial photography, observe characteristics without coming into direct
contact with them. Thus, remote sensing can provide the capability to gather
data about remote, hazardous, or inaccessible areas. Photographs and images
can be used to identify possible sources of pollution and can be taken over
time to track land use changes that may influence water quality, such as
rapid urbanization. Remotely- sensed data can also be used to feed
mathematical models or geographic information systems that aid in nonpoint
source assessments, such as in ranking watershed areas with the highest
potential for runoff. The interpretation of satellite imagery and aerial
photographs, however, is required to connect them to water quality matters;
this process requires specialized skills. In addition, some fieldwork may be
needed to verify the accuracy of image interpretation. Figure 7 provides
examples of remote sensing.

Chapter 4: Technologies for Measuring Emissions From Nonpoint Water Sources

Page 60 GAO- 01- 313 Environmental Protection

Figure 7: Examples of Remote Sensing

Source: The National Aeronautics and Space Administration (Lake Michigan
photo) and the U. S. Geological Survey (Boston Harbor photo).

Models: Computerized models and similar analytical tools can assist nonpoint
source assessment by automating the analysis of the complex relationships
that define how pollutants move through the environment-

Areas of Lake Michigan shown in white indicate elevated pH

Chapter 4: Technologies for Measuring Emissions From Nonpoint Water Sources

Page 61 GAO- 01- 313 Environmental Protection

analysis that would be extremely difficult and time- consuming to do
manually. Models can also simulate the potential effect of various control
actions on pollutant transport. Models have been used in hydrologic
applications for decades, although historically they have been largely
focused on (1) discrete pollutant transport (such as that used in analyzing
pollution impacts from wastewater sources) or (2) individual components of
watershed functioning, such as groundwater movement or urban stormwater
runoff. Recently, EPA has focused on expanding the use and capability of
models in order to meet the demands of assessing nonpoint sources and
developing TMDLs. Many of the improvements made in this area have focused on
making models ?simple.? This simplification has been accomplished by making
the front or back end processing- the user interfaces for data input and
output- more user- friendly; for the most part, improvements have not
focused on modifying the model itself. Therefore, some of the underlying
models may still be complex, but the interface with which a user interacts
has been simplified.

Geographic Information Systems: Geographic information systems (GIS) manage
data according to their spatial or geographic location. GIS can incorporate
remote sensing information (such as land use information, which is often
generated via satellite imagery) and aid in modeling. For example, the
models may be simplified by providing (1) a GIS- based user interface to
assist in data entry and (2) the capability of generating easy- toread maps
to present model results. GIS software is available in varying levels of
sophistication and computer resource capabilities. For example, basic
analytical and geographic capabilities can be performed on an average stand-
alone personal computer. GIS provides a powerful tool for integrating large
amounts of data that could otherwise be prohibitively expensive. As such,
these systems have revolutionized how water quality data can be related to
land use and have provided exponential improvements over prior manual
methods that were used to process and interpret information. One official we
interviewed said that GIS is the

?glue? that holds the data together for assessments of nonpoint source
pollution. Another noted that GIS has ?endless? opportunities for analyzing
data.

Chapter 4: Technologies for Measuring Emissions From Nonpoint Water Sources

Page 62 GAO- 01- 313 Environmental Protection

It is difficult to determine the extent to which a particular nonpoint
source- related technology is being used. The different entities that
conduct nonpoint assessments may use whatever technology they choose and
there is a multitude of these assessments taking place across the country.
However, based on our discussions with a diverse group of individuals
involved in nonpoint source monitoring and assessment, it appears that the
overall use of advanced technologies is limited. Less expensive technologies
or those that require less time and specialized skills to use are more often
used than their more expensive and complex to use counterparts. In addition,
the organizations that are most likely to use advanced technologies focus on
research or in- depth water quality investigations rather than on regulatory
requirements of the Clean Water Act. Many officials that we interviewed told
us that there is a pressing need for better information sharing about the
successes and failures of technologies and techniques used in nonpoint
source assessments.

Several officials we interviewed told us that the increased attention on
nonpoint sources, spurred by numerous TMDL lawsuits, has provided states a
strong incentive to use monitoring technologies and methods that increase
the amount and reliability of water quality information. Two state officials
told us that they expected that the public and pollutant dischargers will
impose increased scrutiny on states? assessments of nonpoint source
pollution for development of TMDLs, and legal challenges may be levied
against some TMDLs. According to many officials we interviewed, the use of
advanced technologies or techniques will hopefully yield a better
understanding of water quality problems and more informed decisions
regarding the needed pollution controls.

Yet, however strong the benefits may be, most states have only capitalized
on a few advanced technologies. According to state officials that we
interviewed, most use automatic samplers and field- based analyzers for at
least some of their monitoring and assessment activities. They noted that
while they can afford to purchase at least some of these instruments and
already have expertise to operate and maintain them, they cannot afford to
buy enough of these instruments to use in the majority of their monitoring
activities. In addition, some officials we interviewed said that users are
sometimes reluctant to experiment with untested or unproven technologies.

States also use ?simple? models- those that have improved user interfaces
and graphic output- when conducting nonpoint source and TMDL analysis. An
EPA official told us that states increasingly use these models Extent to
Which

Improved Nonpoint Source Monitoring Technologies and Assessment Techniques
Are Being Used

Most Used Advanced Technologies and Techniques are the Most Affordable and
Easiest to Use

Chapter 4: Technologies for Measuring Emissions From Nonpoint Water Sources

Page 63 GAO- 01- 313 Environmental Protection

in cases where they must develop TMDLs quickly and where little sitespecific
data exist. These simple models are easily accessible because most of them
are in the public domain, and given the advancements in user interfaces,
they are now easier to use than they were in the past. However, the same
advances that have increased the use of these models also make it easier to
misuse them. Some officials told us that users may not fully understand the
underlying model or know whether they are using the model appropriately. In
addition, an essential component to model usage is calibration and
validation- processes that must be done using site- specific data.
Unreliable and misleading results can be generated if a model is not
properly calibrated and validated. However, as noted above, these models are
increasingly being used in cases were little site- specific data exist.
Several individuals we interviewed expressed great concern over the use of
models in these cases and expected to see challenges to resulting TMDLs.
These concerns were echoed at a recent conference focused on the science
needed to support TMDL development.

While states have limited abilities to use advanced technologies, we found
that research- oriented organizations use advanced technologies and
techniques more frequently in their monitoring and assessment activities.
Research organizations, such as USGS and universities, use automatic
samplers, field- based analyzers, and simple models in their water quality
investigations and devote resources specifically to develop and experiment
with new technologies and techniques. Consequently, they are able to develop
and maintain the specialized expertise needed to use many advanced
technologies. 3

The disparity between the abilities of states and research organizations to
obtain and use advanced technologies and techniques becomes much greater
with the more advanced technologies, such as GIS, remote sensing, and
complex models. In general, only research- oriented organizations and a few
high profile special projects use the most advanced technologies; states
rarely use them for routine assessments.

States? use of GIS, remote sensing, and complex models in their nonpoint
source and TMDL analyses is very limited. Equipment purchases and

3 USGS also cautions that the range of water quality issues these tools can
address is limited. It notes, for example, that the tools do not apply well
to bacteria and not at all to bacteria source tracking. Complex, Expensive

Technologies and Techniques Are Used to a Very Limited Degree

Chapter 4: Technologies for Measuring Emissions From Nonpoint Water Sources

Page 64 GAO- 01- 313 Environmental Protection

training to use the advanced technologies require a significant commitment
of resources. However, water quality monitoring is often found on the bottom
rung of the funding ladder within state programs. Many officials we
interviewed cited the cost of purchasing advanced technologies and the time
needed to acquire the skills to operate and maintain them as major barriers.

Organizations that conduct research or high profile water quality projects,
however, use GIS, remote sensing, and complex models more frequently. For
example, USGS uses these tools to collect, integrate, and analyze water
quality and related data in its water quality investigations. The agency
notes that the use of these techniques, even in limited situations, can
provide very important insights and information. Similarly, the Chesapeake
Bay Program (an interagency program led by EPA) uses these tools to analyze
pollutant dynamics within the Chesapeake Bay ecosystem. High profile state
projects may also use GIS, remote sensing, and complex models. For example,
North Carolina has been using complex models to study nutrients in the Neuse
River- one of the state?s priority water quality projects. These
organizations and projects are focused on obtaining a detailed understanding
of complex water quality problems that may require experimenting with
advanced technologies.

However, research organizations or special projects do not always routinely
use advanced technologies. For example, an analyzer exists to measure
nutrients at low levels and has the potential to provide critical needed
data for the thousands of waters impaired by nutrients, yet its reliability
has not been accepted. Therefore, it is currently being tested at a handful
of universities and USGS. Even if the analyzer proves to be reliable,
however, it is unlikely that it will be used widely because it costs about
$20,000 and the skills of a trained chemist are needed to operate it and
understand its results. One USGS official testing the analyzer said that he
did not envision its widespread use across the agency because of its cost
and the level of specialized skill required to interpret the results.
Similarly, DNA source identification is very expensive and used in only a
limited number of projects.

Many officials that we interviewed recognized the need to improve
information sharing regarding technologies and techniques used in nonpoint
source assessments and TMDL development. Information sharing is particularly
important in an area as decentralized as nonpoint source pollution, for
which assessments tend to be more of an interpretative exercise- often
relying on best professional judgment- Lack of Information

Sharing Misses Opportunities for Improved Efficiency

Chapter 4: Technologies for Measuring Emissions From Nonpoint Water Sources

Page 65 GAO- 01- 313 Environmental Protection

rather than a simple monitoring exercise. While advanced technologies
provide many improvements to users, how these technologies are applied in
specific circumstances is often just as important. One official told us that
he believed that he had duplicated the work of others in his efforts to
modify a streamflow sensor to a particular application. Information sharing
is therefore all the more important in allowing users to capitalize on
lessons learned elsewhere, avoid duplication, and move forward with their
analyses more quickly.

EPA has facilitated some information sharing regarding nonpoint source
monitoring and assessment. For example, EPA holds an annual conference to
share lessons learned from its national nonpoint source monitoring program-
a program that focuses on long- term, intensive monitoring in about 20
waters around the country. The program is intended to evaluate the
effectiveness of nonpoint source pollution controls and improve the
understanding of nonpoint source pollution. In addition, EPA maintains a
periodic newsletter on many aspects related to nonpoint source pollution on
the agency?s webpage. However, as one user pointed out, there is no central
clearinghouse for information about new technologies for use in nonpoint
source assessments. Such a clearinghouse could help connect users who share
common experiences and reduce potentially duplicative efforts. 4

4 In commenting on a draft of this report, the Department of the Interior
noted that the interagency National Water Quality Monitoring Council has
taken some steps toward information sharing through development of a
National Environmental Monitoring Index. The index is intended to provide a
comparison of water quality monitoring methods and includes information such
as the instrumentation employed, sample preservation and storage
requirements, and relative cost. However, information sharing is also needed
regarding analytical approaches and techniques useful in assessments of
nonpoint source pollution. The Department notes that the index could be
expanded to include other technologies and techniques mentioned in this
report, such as GIS and mathematical models.

Chapter 4: Technologies for Measuring Emissions From Nonpoint Water Sources

Page 66 GAO- 01- 313 Environmental Protection

Because many different types of technologies and techniques exist to aid
nonpoint source assessments, the development of improvements to them may
follow one of several different paths. The private sector conducts some
development, such as the case of the automated devices used to sample and
analyze water quality. Other development is primarily federally conducted or
sponsored, such as the case of many of the models in use today. In addition,
users often make refinements, enhancements, and other modifications to
technologies and techniques as more is learned in sitespecific projects.

Several factors make the development of nonpoint source monitoring
technologies or assessment techniques particularly challenging. The first is
the lack of specific monitoring requirements for this type of pollution. In
the past, explicit monitoring requirements for air and wastewater sources
led to a predictable and guaranteed market for individual monitoring
technologies. While states are required to monitor their waters and to
assess water quality, there are no specific requirements for how that
monitoring should occur and what technologies or methods should be followed.
Hence, as the instrument manufacturers we interviewed pointed out, there is
no clearly defined market for nonpoint source monitoring technologies and
assessment techniques.

A second challenging factor is the size of the potential market for nonpoint
source monitoring technologies and assessment techniques. Water quality
monitoring and assessment have historically received less funding than other
water and environmental programs. As such, instrument manufacturers we
interviewed acknowledged that the market for their products was fairly
small. For example, an official from a GIS developer said that developments
in GIS technology have largely been geared toward well- funded applications,
such as transportation planning and facilities management, and not for
natural resources management. In addition, the president of one
manufacturing company, who was modifying a defenserelated sensor to the
water quality market, told us that the return on investment takes longer in
the environmental market than for other technology markets. He said that
unlike other technology areas where users are quick to purchase new
technologies, the environmental market is generally not very responsive to
new technologies, partially due to resource constraints.

Modeling- an area in which much of the past development has been federally
conducted or sponsored- similarly suffers from a lack of investment. While
most needs are being met through existing models, some users told us that
solving very complex nonpoint source pollution Factors That

Influence Development of Improved Nonpoint Source Monitoring Technologies
and Assessment Techniques

Chapter 4: Technologies for Measuring Emissions From Nonpoint Water Sources

Page 67 GAO- 01- 313 Environmental Protection

problems requires more advanced tools than exist today. In addition, some
users noted that the basic models have received no major modifications in
several decades. However, progress on improving the models themselves is
limited mainly because EPA- the agency that has traditionally conducted or
funded a large portion of water quality model development in the past- has
cut funding in this area by about 75 percent since the mid1990s. According
to an official from an EPA laboratory primarily responsible for this work,
the agency plans to pursue improvements to existing models and work on new
models, but progress will be slow given the limited funding devoted to this
area.

The lack of information sharing- discussed earlier as a problem impeding
wider use of advanced technologies- is a third problem that constrains
development of new or improved technologies and techniques. As noted
previously, users are sometimes reluctant to experiment with new and
potentially unproven technologies. However, until users do so and document
their experiences, it is not clear what additional development is needed or
where it could be of most value. For example, according to several of the
users that we interviewed, information on the effectiveness of various best
management practices needs to be improved. While some users thought that
additional research was needed to determine the effectiveness of such
practices, others thought that inventorying the work already done would
yield most of the information needed. However, until an inventory is done,
it is not clear what needs for technology and tool development remain.

Recent emphasis on addressing polluted waters has placed increased
importance on identifying nonpoint source pollutant discharges quickly,
accurately and at lower costs. However, the absence of explicit nonpoint
source pollution monitoring requirements, combined with the historically low
level of funding being devoted to nonpoint source monitoring, has
discouraged wider investment in this area.

We found these challenges to be further compounded by a scarcity of
information concerning the numerous data, technologies, and analytical tools
that are used in the multitude of nonpoint source assessments that are being
conducted each year. The scarcity of such information makes it difficult to
identify which tools are most useful under specific circumstances. This
additional complication, however, could be substantially alleviated if a
centrally situated organization- such as EPA- routinely catalogued and
publicized information about which monitoring technologies and assessment
techniques work, and why they work. We Conclusions

Chapter 4: Technologies for Measuring Emissions From Nonpoint Water Sources

Page 68 GAO- 01- 313 Environmental Protection

believe that doing so could go a long way in (1) maximizing the relatively
small investment currently being made in monitoring and assessing nonpoint
sources, (2) providing greater assurance that resulting recommendations for
pollutant controls are cost- effective and successful, and (3) guiding the
efforts of those attempting to identify the most promising new technologies
and other tools for investment.

To improve the sharing of information and reduce duplication, we recommend
that the Administrator, EPA, direct the Office of Water to develop a
clearinghouse and/ or locator for monitoring technologies and assessment
techniques that are used for assessing pollutant contributions from nonpoint
sources and developing TMDLs. Such a clearinghouse should include (1) a
mechanism whereby users could obtain and update information regularly and
easily and (2) information provided by EPA and the other federal agencies
that collect and analyze water quality conditions.

EPA did not comment on the material in this chapter. The Department of the
Interior said that it agreed with our recommendation that EPA develop a
clearinghouse and/ or locator for monitoring technologies and assessment
techniques that are used for assessing pollutant contributions from nonpoint
water pollution sources and for developing Total Maximum Daily Loads. It
suggested, however, that the report note that the interagency National Water
Quality Monitoring Council has already made some progress in this direction
through the establishment of a National Environmental Monitoring Index. We
added language to this effect in this chapter, and incorporated several
other technical comments and clarifications suggested by the agency. The
text of Interior?s letter is included in appendix. I. Recommendations

Agency Comments

Appendix I: Comments From the Department of the Interior

Page 69 GAO- 01- 313 Environmental Protection

Appendix I: Comments From the Department of the Interior

Appendix I: Comments From the Department of the Interior

Page 70 GAO- 01- 313 Environmental Protection

Now on p. 61. Now on p. 59. Now on p. 55.

Now on p. 53. Now on p. 52.

Now on p. 52.

Appendix I: Comments From the Department of the Interior

Page 71 GAO- 01- 313 Environmental Protection

Now on p. 66. Now on p. 63.

Now on p. 62.

Appendix II: GAO Contact and Staff Acknowledgments

Page 72 GAO- 01- 313 Environmental Protection

Steven Elstein, Assistant Director, (202) 512- 6515 In addition to the
individual named above, Michael Hix, Jason Holliday, and Patricia McClure
made key contributions to this report. Important contributions were also
made by Chuck Bausell, Tim Guinane, Karen Keegan, and Jonathan McMurray.
Appendix II: GAO Contact and Staff

Acknowledgments GAO Contact Acknowledgments

(160547)

The first copy of each GAO report is free. Additional copies of reports are
$2 each. A check or money order should be made out to the Superintendent of
Documents. VISA and MasterCard credit cards are also accepted.

Orders for 100 or more copies to be mailed to a single address are
discounted 25 percent.

Orders by mail:

U. S. General Accounting Office P. O. Box 37050 Washington, DC 20013

Orders by visiting:

Room 1100 700 4 th St., NW (corner of 4 th and G Sts. NW) Washington, DC
20013

Orders by phone:

(202) 512- 6000 fax: (202) 512- 6061 TDD (202) 512- 2537

Each day, GAO issues a list of newly available reports and testimony. To
receive facsimile copies of the daily list or any list from the past 30
days, please call (202) 512- 6000 using a touchtone phone. A recorded menu
will provide information on how to obtain these lists.

Orders by Internet

For information on how to access GAO reports on the Internet, send an e-
mail message with ?info? in the body to:

Info@ www. gao. gov or visit GAO?s World Wide Web home page at: http:// www.
gao. gov

Contact one:

 Web site: http:// www. gao. gov/ fraudnet/ fraudnet. htm

 E- mail: fraudnet@ gao. gov

 1- 800- 424- 5454 (automated answering system) Ordering Information

To Report Fraud, Waste, and Abuse in Federal Programs
*** End of document. ***