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National State Auditors Association (NSAA) 
Joint Study of Water Quality Issues
Presentation at the NCSL Annual Meeting (August 12, 2001)
Deborah Loveless, Assistant Director, Tennessee Division of State Audit

NSAA chose water quality as the topic for its 2000 joint performance audit project. NSAA has initiated joint studies on various topics in each year since 1989. The states plan for these studies jointly, but the focus of individual states' audits vary somewhat. At the end of each project, the "lead" state on the project issues a joint report that summarizes issues identified by the participating states. The water quality report is available at:

http://www.comptroller.state.tn.us/sa/reports/pa00023j.pdf.

• Participating states' water quality standards for drinking water and surface water usually met or exceeded EPA standards.

• Various states have had difficulty monitoring for compliance with surface and drinking water quality standards. Some of the problems have included insufficient review of "nonmajor" facilities, water sampling irregularities, and questions about the reliability of self-reported data from pollution sources or water treatment systems.

• Several states reported that facilities' water quality permits have not been issued in a timely manner.

• Some states reported slow progress in implementing EPA requirements related to "total maximum daily loads" (TMDLs).

• Several states found problems in the enforcement process, including untimely enforcement action, lack of follow-up of long-term compliance schedules, not enforcing monetary penalties, inconsistent penalty structure, and poor record keeping and case tracking.

• Most of the states participating in the joint audit did not examine nonpoint source pollution in detail, but one state (Kentucky) did. It found serious problems in animal feedlot permitting, sewage disposal, coal mining permit monitoring, and abandoned underground mine mapping.

• Some states' information systems contained inaccurate information on the results (and possible violations) listed on discharge monitoring reports.

• Several states found that not all sanitary surveys were being conducted, and deficiencies identified through the survey process were not always followed up.