Water Pollution:

Serious Problems Confront Emerging Municipal Sludge Management Program

RCED-90-57: Published: Mar 5, 1990. Publicly Released: Apr 11, 1990.

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Pursuant to a congressional request, GAO assessed the Environmental Protection Agency's (EPA) development of a mandated municipal sludge management program, focusing on: (1) the status of EPA and state municipal sludge management efforts; (2) potential obstacles to permanent program implementation; and (3) key issues concerning EPA development of technical sludge standards.

GAO found that: (1) few states were willing to fully participate in the program because of limited resources, and participating states' programs omitted key responsibilities; (2) EPA had not completed its inventories of priority sludge-generating facilities; (3) EPA did not properly enforce or approve technical sludge standards; (4) overly stringent technical standards could eliminate most beneficial sludge uses; and (5) regulatory delays and uncertainties have inhibited states' participation in the interim program and willingness to seek approval for the permanent program.

Recommendations for Executive Action

  1. Status: Closed - Implemented

    Comments: EPA completed a feasibility study in January 1991 on whether the current permit compliance tracking system could also track sludge permit requirements. EPA plans to have its system in place to track sludge permit issuance, record permit limits, and store sludge monitoring data by summer 1992. EPA made some progress in tracking sludge conditions through its automated systems but did not include all of the data elements GAO recommended.

    Recommendation: To improve regions' and states' performance in the interim program and to lay the foundation for their implementation of the permanent program, EPA headquarters needs to build on its ongoing efforts to improve the way it tracks their performance. Specifically, the Administrator, EPA, should direct that modifications be made so that EPA can track the: (1) number of permits that are required to include sludge conditions as well as the number that actually do include the conditions; and (2) content of the conditions, such as whether pollutant concentration levels are being included for different sludge use and disposal practices.

    Agency Affected: Environmental Protection Agency

  2. Status: Closed - Implemented

    Comments: Due to a lack of resources, EPA will not begin to develop elements 1 or 2 until 1995. EPA does not plan to develop any special guidance for headquarters oversight of regional or state enforcement activities for sludge but will follow the same procedures used for all water enforcement programs. As a result, these enforcement components will not be in place prior to the permanent sludge program.

    Recommendation: To improve the prospects for an effective permanent sludge program, the Administrator, EPA, should take measures to ensure that a strong enforcement component is in place when the permanent sludge program begins. Among the key elements that should be included are: (1) criteria for significant noncompliance so that enforcement priorities can be determined; (2) criteria for timely and appropriate enforcement so that the type and timing of enforcement is known to both regulators and publicly owned treatment works; and (3) effective oversight of EPA regional and state enforcement efforts by headquarters.

    Agency Affected: Environmental Protection Agency

  3. Status: Closed - Implemented

    Comments: EPA conducted a State Funding Study in January 1989 and is implementing the recommendation, but this does not respond to the recommendation that sludge program officials assist states in seeking alternative ways to fund state sludge programs. EPA is planning further action on this recommendation.

    Recommendation: Given the problems posed by funding constraints for the sludge program and the prospect that EPA alternative financing efforts could help alleviate these types of problems, the Administrator, EPA, should direct its sludge program officials to supplement those broader agency efforts by assisting publicly owned treatment works and state sludge officials in seeking alternative ways to fund state sludge programs.

    Agency Affected: Environmental Protection Agency

  4. Status: Closed - Implemented

    Comments: Further delays have continued, despite the recommendation that they be "minimized." The newest deadline is July 1992; but the spirit of the recommendation, to issue the regulations without further delay, was not observed.

    Recommendation: In light of the long history of delays in issuing technical sludge regulations, the prospect of continuing difficulties, and the significance of timely development of those regulations to the emerging national sludge management program, the Administrator, EPA, should closely track EPA progress in its efforts to promulgate them. Specifically, the Administrator should ensure that further delays are minimized as EPA incorporates the views of interested parties on the draft technical regulations it proposed in February 1989.

    Agency Affected: Environmental Protection Agency


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