'ironmental Protection
.Office Of Water
J4203)
EPA 833-R-96-009
-October 1996
'roving Industrial Pretreatment
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, Challenges,
iect Ideas
s From EPA Sites Visits
ia, Indiana. And
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Improving Industrial Pretreatment:
Success Factors, Challenges, and Project Ideas
Findings from EPA Site Visits to California, Indiana and Virginia
.-Preparedfor:
Office of Policy, Planning and Evaluation
U.S. Environmental Protection Agency
401 M Street, SW ' ',- ,
Washington, DC 20460
Prepared by:
Industrial Economics, Incorporated
2067 Massachusetts Avenue
' Cambridge, MA 02140
October 1996
Common Sense Initiative
Metal Finishing Sector
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ACKNOWLEDGEMENTS
This report was prepared under EPA contract 68-W4-0041 by Doug Koplow, Ellen Clark/
and Christine Tayerna of Industrial Economics, Incorporated. Valuable review of the information
was provided by many people at the U.S. EPA including Greg Arthur, Robert Benson, Pat Bradley,
Jim Casey, Matt Gluckman, Doug Jamieson, Mamie Miller, Wendy Miller, Keith Silva, and Greg
Waldrip. Important review was conducted outside EPA as well, by John Craddbck ofthe Muneie
Bureau of Water Quality in Indiana; Guy Aydlett and Bernie Strohmeyer of the Hampton Roads
Sanitation District in Virginia; Juan Mariscal ofthe Narragansett Bay Commission in Rhode Island;
and Curt Spalding of Save the Bay. . .
- ' ' - ' . •,''->•-•-.. X ''";".'''•' " . - "
Without the enthusiastic participation of the many pretreatment professionals from around
the country, this document would not have been possible. We extend our thanks to the many,staff
at the following programs who took the time and interest to share their thoughts with us: California -
City of Escondido's Hale Avenue Resource Recovery Facility, City of West Sacramento POTW,
County Sanitation Districts of Orange County, East Bay Municipal Utility District, and Union
Sanitation District; Indiana - Muncie Sanitary District, Cityof Elkhatt Wastewater treatment Utility,
City of Fort Wayne Wastewater Treatment Plant, Connersville Utilities, and Richmond Sanitary.
.District; Virginia - Alexandria Sanitation Authority, City of Richmond Wastewater Treatment Plant,
Hampton Roads Sanitation District, and Hopewell Regipnal Wastewater Treatment Facility.
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TABLE OF CONTENTS
Executive Summary . . - '• • •
Introduction . .
Attachment 1: Interview Guidelines ; ...:.
Attachment 2: Summary of Issues and Recommendations by Program Area
Attachment 3: Summary of Top-Ranked Projects Identified Through Site Visits ;
Attachment 4; Trip Report from California Site Visits
Attachment 5: Trip Report from Indiana Site Visits
Attachment 6: Trip Report from Virginia Site Visits . : ..-'.'•
Attachment 7: Summary List of All Potential Projects Suggested During Site Visits
ES-1
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EXECUTIVE SUMMARY
Early in 1996, an interview team from EPA headquarters visited fourteen industrial
pretreatment programs throughout California, Indiana, and Virginia, the trips were undertaken as
part of EPA's Common Sense Initiative (CSI) for the Metal Finishing industry in recognition that
the quality of a POTWs pretreatment'prograin can have an important impact on metal finisher
compliance with the Clean Water Act. , , .
" The goals of this project were twofold: to improve the capabilities of the lowest tier POTWs
and to provide the most effective POTWs with increased flexibility to achieve higher environmental
quality at a lower cost. Programs visited represented a wide range of capabilities, from top-tier
winners of pretreatment awards to small programs under EPA or state enforcement action for
inadequate performance. . Strong programs-tended to have technically-skilled staff, adequate
resources, 'good information on their industrial users, and proactive and positive relationships with
the regulated universe of dischargers. Weaker programs were not only lacking in these areas but also
often faced politicalinterference in carrying out their mission. . .
The many perspectives heard on this trip suggested a few common areas where pretreatment
staff felt EPA involvement could be of great benefit to leveraging their performance and improving
environmental quality: . . • :
• Upgrades toPIPES on-line information system. Addressing the common
need for faster access to a wider range of information on pretreatment and the
industrial users, a high-priority effort to upgrade PIPES would give,the
programs real-time access to a host of core program resources not easily
3j$er> , '• •••*.-' ' - - ' • ' " • "
available now. . . , :
• Increased transfer of pretreatment information systems. EPA could
facilitate improved information management within the programs by
identifying and promoting mechanisms that allow pretreatment programs to
; share information system development costs with other POTWs. and with
. omer branches of their own POTW.
• Training Videos. Focusing on program basics, sampling,.and conducting an
inspection, the videos would bring expertise to small, struggling programs
that do not have the budget or staff to travel to more traditional training
activities. / / - "
• Cost accounting and budgeting. By providing examples of good budgeting
and cost accounting practices, this,EPA project would provide pretreatment
programs with useful tools to demonstrate the cost-effectiveness of their
programs and to better understand me financial impact of certain types of
--•'. ' ' -. •"" '. , • ' '•• ' -, ES-l ' ;'; -. : .":.- • : .:\. - . ";.';
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discharges on their sewage treatment system. ' .
"Guidance to the Guidance.." A need expressed especially by the smaller
programs, this guidance wpulcLserve as.a "roadmap" to help new coordinators;
prioritize their learning and filter the massive amounts of guidance now
available. The goal of the project is to quickly bring programs to a functional
level, and to help structure incremental learning.
Choosing a contract laboratory. Many programs were not confident in
their ability to evaluate the quality of the contract laboratories they relied on
for at least some of their analytical requirements, despite the importance of
this choice in ensuring an effective pretreatment program. This guidance
would provide them with the tools to evaluate laboratory performance and
'make better choices regarding contract laboratory services.
Increased regulatory flexibility for top performers. A number of
programs complained that certain regulations required substantial staff time
with little or no environmental benefit. A possible pilot study would give a
top-performing POTW the flexibility to redeploy the resource's now used to
meet these regulations towards areas of higher environmental benefit.
ES-2
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INTRODUCTION
Early in 1996, an interview team from EPA headquarters visited fourteen industrial
pretreatment programs throughout California, Indiana, and Virginia. The trips were part of EPA's
Common Sense Initiative (CSI) for the Metal Finishing industry, initiated in 1993 by EPA
Administrator Carol Browner. CSFs purpose is to use a less-adversarial regulatory approach,
working-with industry, government, the public, and envirdnrnentalgroups to achieve more efficient
environmental protection. '
Through working with the metal finishing industry, EPA determined that pretreatment
programs, managed5 by the localwastewater treatment authorities throughout the country, are an
extremely important regulatory factor in metal finishing operations. This reflects the large
discharges of water associated with metal finishing processes. The metal finishing industry has
shown great interest in seeing improved .pretreatment programs, since effective programs help
finishers achieve and maintain environmental compliance while also forcing negligent, firms to
upgrade or cease production, thereby preventing them from undercutting the environmentally-
responsible firms. Environmental participants on the Metal Finishing subcommittee were equally
supportive of the effort because of the large potential to improve water quality through more
effective pretreatment programs. ,
Programs visited represented a wide range of capabilities, from top-tier winners of
pretreatment awards to small programs under EPA or state enforcement action for inadequate
performance. Despite the diversity of the programs, there were many areas of agreement Some of
the practices that the best programs felt contributed to their success were areas where struggling
programs knew they needed to improve. The day-long interviews at each facility included a range
of people, including the pretreatment program coordinators, lab personnel, inspectors, samplers, and
utility-managers. In a number of cases, the team also interviewed local industrial users (most often
metal finishers) to get their perspectives oh the programs. The results of these interviews have been'
summarized in this document. As was agreed,prior to the site visits, the names of specific
individuals or programs have been excluded from this report.
Goals of the Site Visits
The goals of this project were twofold: to improve the capabilities of the lowest tier POTWs
so that they can manage their industrial users in such a way as to reduce mass pollutant loadings
without unnecessarily limiting or curtailing industrial activity; and to provide the most effective
POTWs with increased flexibility to achieve higher environmental; quality at a lower cost.
h ' ' ' • • ' • -, ' "' •• - ' , ' ' '. '' .'' . '
The interviews were successful in both of these areas. Top-tier programs shared many
aspects of what they feel make them effective; struggling programs were equally candid discussing
theif limitations and how to address, them. In addition, every program visited had numerous
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suggestions to both EPA and the Common Sense Initiative about where regulatory flexibility would
reduce workloads and costs while improving or maintaining environmental quality.
The results of the visits, summarized in this report, outline some clear needs of the,
pretreatment programs and highlight effective directions for EPA involvement in the pretreatment
arena. The interview team hopes that the insights we have collected from the many, dedicated
pretreatment staff across the country will help EPA to reallocate priorities and budgets to better
reflect the expressed needs of the field staff. >
Site Visit Logistics
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As mentioned above, the .interview team visited fourteen pretreatment programs in three
states:'
• California: East Bay Municipal Utility District, Union Sanitation District,
City of Escondido, City of West Sacramento^ and County Sanitation Districts
of Orange County. .
•*•'•'••:.'• ". '. ; • ''. • c ,
1, , " ' " „, " " ,' , . ' _
• • Indiana: Elkhart, Fort Wayne, Richmond, Connersville, Muncie. .
• Virginia: Hampton Roads, Hopewell, Richmond, Alexandria
The interview team varied somewhat in the" three states, but contained representatives from the
Office of Policy, Planning, and Evaluation; the Office of Water; and the Office of Enforcement and
Compliance Assurance. EPA staff from the Region 5 and 9 offices also participated on a number
of the site visits. Additional support was provided by Industrial Economics, an EPA contractor. The
multi-office approach gave the interview team a range of perspectives and skills that made the visits
more successful.
Overview of Report Structure
/ . -
This report contains a brief summary of the major findings of the interviews, followed by a
number of attachments containing more detailed summaries of the site visits:
'',.'! ( ,,' ' .' i •;'• :,' |, ,
• Attachment 1: Interview Guidelines
• Attachment 2: Summary of Issues and Recommendations by Program Area
• Attachment 3: Summary of Top-RankedProjects Identified Through Site Visits
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• Attachment 4: Trip Report fromCalifdmia Site Visits
S ' , " • ' ' •'''•: • , I .'.''.•---
'! • Attachment 5: Trip Report from Indiana Site Visits
, ',^.9 Attachment,6: Trip Report from Virginia Site Visits • .
. ^ ,'.•--.'--.:•, ' ' ' " '
• Attachment?: Summary List of Ail Potential Projects Suggested During Site Visits
MAJOR FINDINGS OF THE INTERVIEWS
Major findings of the interviews are described in three sections. The first section discusses
common themes raised by the various programs; there was a rather remarkable consistency in
information reported-across POTWs of different- sizes and performance levels regarding the
challenges they face aridthe factors mat make a program successful. The second section identifies
some of the unmet needs of struggling pretreatment programs. The third section identifies common
challenges or needs of both the top-tier and the struggling programs.
General Issues
Common elements repeatedly brought up by pretreatment staff included:
• Enforcement is extremely important. Where local politics prevented the
pretreatment program from enforcing the law against lUs or where
insufficient or poorly trained staff precluded running an effective
pretreatment program, enforcement was critical. All of the programs visited
that were under current or past EPA enforcement actions said they were
grateful the action had been taken. The pressure from outside enabled them
to get rid of incompetent staff, obtain additional resources, and get the
program back on track.
• Cooperation works better than confrontation. Once mere is respect for
the necessity of pretreatment (i.e., ILJs aren't flouting the law), a cooperative
relationship for solving discharge problems has been most effective in
ensuring compliance.
• Establishing "control" over an IU production process is a critical goal.
Successful programs worked hard with lUs so that the industrial process was
well understood, and the impact on water quality from changes in production
parameters could be predicted ahead of time. The technical expertise of
pretreatment personnel was an important factor in achieving this level of
control. •'.."•
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POTWs felt that some EPA regulations made little environmental or
economic sense. Some EPA regulation of POTWs requires them to do things
that they don't feel have any particular environmental benefit, but these
activities use up staff time and resources. .
Access to timely information is critical but often missing. Information
management within pretreatment programs, as well as access to important
information of a more general type (e.g., pollution prevention), exists in very
few programs.
Self-reported IU test data generally viewed with skepticism. The POTWs
consistently said that industry self-reported tests found substantially lower
constituents of concern than did the POTWs own sampling. Self-reported
data was heavily discounted by the pretreatment staff. This has important
implications for CSI-related efforts to provide flexibility to industry through
reduced testing.
„ • ' ''- •'' i i • <•' '- ;' :,' " ' '•, , '•' '•'' ' "F , "•"' ' v, ' *' s- '
Staff retention is important in building a good program. Pretreatment
staff must have knowledge across a wide range of topics, skills that can take
years to develop. Upgrading staff skills and retaining core staff were
extremely important in assuring quality programs, though sometimes difficult
for the smaller programs. -
Pretreatment staff need direct oversight of dischargers in order to run
an effective program. Many programs receive wastes from industries in
surrounding municipalities, where an interjurisdictional agreement governs
pretreatment access to discharging industries. These agreements often fail to
give program staff the oversight required to ensure proper .environmental-
performance.
TJnmet Needs of Struggling Programs
Struggling programs sometimes faced an uphill battle in improving their performance. There
were a number of common needs expressed by these programs.
• Special needs of small programs. Given the diversity of required
knowledge for pretreatment staff, as well as the role that local politics
sometimes plays in the programs, it is not surprising that staff in some of the
' small programs sometimes struggled to meet the heavy program demands.
'Common needs of these programs include prioritizing training activities for
new coordinators and key staff, overcoming political pressures, and
demonstrating the value of pretreatment to the local economy.
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Information filtering. Struggling programs often need help managing and
processing large amounts of regulatory, industry, and program information.
In addition to simply writing.regulations more clearly, solutions such as
common language summaries of new regulations would help reduce this
.burden. , ' / • '.''•.,
More training options. Training staff was a critical need in all of the
struggling programs. New training alternatives that did not require expensive
registration fees or travel were a high priority for these programs.
Common Challenges Across Most Pretreatment Programs
Even successful programs face challenges in trying to make'their programs..more effective.
TheInterviews identified several areas where most programsiface challenges:
• Cost accounting and budgeting. This was a major weakness across almost
every program. Without good information, program coordinators had a
difficult time making efficient decisions, demonstrating the value of.
''- pretreatment to the locality, or sending the proper economic signals,to
, industries about priority areas in which to invest resources for pollution
prevention or improved pollution controls. ..
• More rapid access to better information. Both large and small programs
thought access to better information would help them do their jobs better.
, the areas suggested for improvement included a comprehensive on-line
- repository of all EPA guidances, an on-line database on pollution prevention
opportunities for core discharging industries,and improved data management
systems within programs. ,., / ,
• Demonstrating program efficiency and effectiveness, Pretreatment
coordinators described their programs on a.number of occasions as the "poor
stepchild" to other water programs. While strongly convinced that
pretreatment was an extremely effective and efficient mechanism by which
. . to protect the quality of the receiving waters, program coordinators were
seekmg better ways to demonstrate their convictions tangibly to the broader
utility and the broader community. The impending threat of privatization,
mentioned by most programs visited, added a certain urgency to this need.
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POSSIBLE METHODS TO ADDRESS PROGRAM NEEDS
Using the interview comments, EPA staff developed a list of possible actions to address the
central issues identified through the site visits (Attachment 7). This list was then ranked to narrow
the.actions to those felt most likely to have a positive impacts (Attachment 3). These top-ranked
projects are described briefly below:
• Upgrades to PIPES on-line information system. Addressing the common
; need for faster access to a wider range of information on pretreatment arid the
industrial users, a high-priority effort to upgrade PIPES would accelerate the
transition from paper to on-line distribution of information with many
peripheral benefits. Specific components of this upgrade include:
Putting old EPA guidance on-line.
Converting all system documents to a standard portable digital
format.
. - Converting the site to a full World Wide Web capabilities to improve
access, and make using the site easier for users.
' Uploading "plain English'* updates and summaries of regulations of
..', •" ,' 'concern,- . . , " '.. .' • .'!,,'„
— ' Creating a regional calendar, to which regions and states could add
activities. . • ..-'.-'.'
Creating additional content for the system, including information on
P2, changes facing pretreatment programs as their NPDES permits
.are renewed, and compiling national SNC/NOV summaries to
increase leverage of POTWs over recalcitrant industries.
• Increased transfer of pretreatment information systems. This project
wquld help identify and promote mechanisms that allow pretreatment
programs to share information system development costs with other POTWs
and with other branches of their own POTW, thereby reducing the costs of
1 , j , "f ' " ,
improved internal information management.
• Training Videos. Focusing on program basics, sampling, and conducting an
• inspection, the videos would bring expertise to small, struggling programs -
that do not have the budget or staff to travel, to more traditional training
activities.
• . Cost accounting and budgeting. By providing examples of good budgeting
and cost accounting practices, this project would provide pretreatment
programs with useful tools to demonstrate the cost-effectiveness of their
programs and to better understand the financial impact of certain types of
discharges on their sewage treatment system.
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"Guidance to the Guidance." This guidance would help new coordinators
prioritize their learning and filter the massive "amounts of guidance now
available. The goal of the project is to quickly bring programs to a functional
level, and to help structure incremental learning, r
Choosing a contract laboratory. Solid analytical results are a critical input
to a successful pretreatment program, yet many programs were riot confident
in their ability to evaluafe the quality of the contract laboratories they relied
on for at least some of their analytical requirements.' This guidance would
provide them with the tools to evaluate laboratory performance and make
better choices regarding contract laboratory services.
Increased regulatory flexibility for top performers. A number of
programs complained that certain regulations required substantial staff time
with little or no environmental benefit. A possible pilot study would give a
top-performing POTW the flexibility to redeploy the resources now used to
meet these regulations towards areas of higher environmental benefit.
7
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Attachment 1:
Interview Guidance for POTW Site Visits
CSI INTRODUCTION
Overview of CSI and importance^ of pretfeatment issues to metal finishing
sector. . -
Goal of project to learn from pretreatment program staff: what works, what
doesn't; and to hear their suggestions for making the program work better.
GENERAL INTRODUCTION
v • ' . ' ' ' ''''".'..' "". • • \ • •'-
Purpose: To set the scene, prior to biasing interviewee with certain types of questions that
could make them defensive. .? '. , ,
1) Program Background. Ho\y many employees are working on pretreatment? Where is the
pretreatment program located in the local government structure? . What is the
authorizing/funding authority for the POTW -^ municipality or regional authority? Describe
your Industrial Users, their products, and their discharges. How many are metal finishers?
2); Successes. What have been your biggest successes (individual or overall POTW) in the pre-
treatnient program during the past three years?
3.) Challenges. What are the biggest problems/challenges you face in making your pre-
treatment program work more effectively? What would help you most in being able to better
address tnese problems? / • • ^
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4). - Identifying lUs. How do you locate/identify lUs? What process do you use to. categorize
them? Do you experience any problems locating and categorizing metal finishers?
5) Permitting TUs. What are some particularly effective or efficient aspects of your program
to permit or otherwise apply pretreatment requirements to the noridomestic users addressed
in your program?
6) Pollution Prevention. Does your operation (both within the POTW and working with IUs)
emphasize pollution prevention? .What pollution prevention initiatives have you found
successful? What have not worked as you had expected? What were the main barriers in
implementing pollution prevention? ,. . . '
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7) Preventing Media-Shifting. (Explain this what is meant here - overall waste management
as "opposed to moving pollution from one media to another). Do you operate on a
multimedia basis? How do you factor multimedia considerations into your operations?
8) Suggestions to EPA Regarding Oversight. What would you change about the existing
NPDES program/pretreatment programs?
9) Suggestions to EPA Regarding Focus. Where should EPA/State devote compliance
assistance/enforcement resources in the next few years? Would you change the. roles of the
states and EPA regarding the pretreatfnent program? How?
EVALUATING THE PRETREATMENT PROGRAM
tO) Measuring Results. How do you assess the environmental results of the pretreatment
program?
• Have you established local limits and how are these implemented?
• Do you track trends in influent, effluent, and sludge loadings over time?
• What is the quality of the POtWs sludge?
11) Controlling Discharges. What approach do you use to control pollutant discharges from
industrial or commercial customers? How does the POTW prevent upsets? How do you
respond to strange influent at the plant? Do focus exclusively on lUs or do you look at
commercial and domestic contributions also?
12) Sampling Strategy. Please describe your strategy for sampling lUs. Specifically, what
frequency is sufficient? What balance do you strike between self-reported data and POTW
inspections? How do you ensure sampling accuracy?
13) Inspection Strategy. Please describe the strategy and objectives for your inspection
program. , .
14) Enforcement Strategy. Please describe the strategy and objectives of your enforcement
program. What is the level of management support for enforcement activities?
15) Assuring Consistent Implementation. HOW do you assure that the pretreatment program
is implemented consistently in all political jurisdictions served by the POTW? How is the
communication between the inspectors, the plant operators, the sampling personnel, the lab
personnel coordinated between themselves and with the program coordinator? (May be
simple for small POTWs).
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16) Benchmarking. Do you .study other treatment plants for new ideas? .. _
• " ' . . . - - , , '" -' • _ >/"••.
17) Future Goals. Please describe your goals for the pretreatment program over the next three
' to five years. • ' ,"'•,:
EMPLOYEE ISSUES
18) Overview. Please describe the number and organization of pretreatment employees. How
many years has the program coordinator worked at the POTW? How long has the
coordinator been working in the environmental field? Provide similar information for the
staff. (May "have been partly covered during the introductory program background
discussion)." x
19) Staff Turnover. Is staff turnover a problem? If so, what steps have been taken to retain
staff? • "...•-.'.-..' ' •:-'•-'. • '.'• • ' / -/' .". -.''',
EDUCATION/TRAININGf ACTIVITIES AND INITIATIVES
Purpose: To learn which areas the POTW thinks are most .important; to identify current
gaps; to identify why past efforts may not have workedv .
20) Internal Training. Describe your training program for staff and the resources you have
^available for training activities. How important is training in running a successful
pretreatment program? How many state, or EPA training events-have you and your staff
.attended over the past year? Did you find them useful?
21) External Training. Describe any training programs started (or used) by your office to
educatelUs. . .. ' 1
22) Additional Training. Do you think additional POTW pretreatment training/outreach is
needed?: Of what type and by whom?
23) Useful Guidance Documents. Do you use any pretreatment program guidance documents
or manuals regularly? Would you recommend any particular guidance documents to other
pretreatment professionals? .
PRETREATMENT RESOURCES AND COST ACCOUNTING
24) Budget. How is your program funded? What trends do you foresee?
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25)
26)
27)
28)
29)
Demonstrating Value-added. What approach do you use to illustrate to lUs and taxpayers
that your pretreatment services are valuable and efficiently provided?
Cost Accounting. Do you calculate the cost of handling particular IDs and/or particular
types of pollutants on the overall system? Are these costs charged back to specific
dischargers? To industrial dischargers overall, or paid for by all dischargers?
Impact of IU Fees on Economic Activity. Please describe what impact full cost recovery
from IUs has had (or would have) on the industrial base located in your service area.
Investment Decisions. What information do you review to make decisions regarding
investments in equipment, training, outreach, or consulting services?
111 , , , , ' '„ '' .' •,','.',, ' ' •' / .. • /''.'."' I i
Contracting Services. Do you, or have you, considered using consultants or contractors-for
parts of your program? How did you make this decision? If not, do you ever evaluate
whether outsourcing would be attractive for certain portions of your program?
INFORMATION SYSTEMS
30) Overview of Information Systems. Please describe any information systems that are being
used to support the pretreatment program. Are these systems linked to the rest of the
POTW? Have there been any past attempts to build information systems that did not provide
the expected benefits to the program?
Areas of Interest Include:
• Enforcement, compliance, permitting systems,
• Tracking trends and variances.
, • Cost accounting.
• Targeting enforcement and/or outreach.
• Expert systems on pollution prevention opportunities for particular sectors.
311 Ensuring Compliance. How do you gather and maintain data to determine pretreatment
program compliance? Describe how sampling, testing, chain of custody, and pretreatment
pro-am compliance determinations are handled. What steps do you take to get
noncbmplying IUs into compliance? - .
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OUTREACH
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32) Industrial Users. Do you meet, regularly with your industrial users? How rwould you
.characterize your relationship? ; ' ' .
33) . Local and State Government Describe the relationship between the program coordinator
and his/her management. What dialog occurs between _ the program and the mayor/city
'council/regional authority? What effect does the Chamber of Commerce have on the
program functioning properly? What is the level of local government support for the
pretreatment program?
34) General Public. What outreach activities for the general public do you undertake? Have
there been any issues over the past three years that have generated substantial interest from
- citizens or public interest groups? -
ISSUES FOR CLASS 1 AND CLASS 2 POTWS
Class 1 . ' ' ' .•'.'/.- ' '- ' ' • • - "''-., -y' ' --,.;.-, . ,; - '.. " "
35) Reasons for Non-compliance. What are the- key contributing factors to your past
pretreatment program noncompliance? What steps have you taken to overcome the barriers
to compliance?
36) IU Non-compliarice. . What steps have taken to achieve aii improved level of IU
. complaince? What methods have you found effective in changing a noncompliant IU into
; a compliant rone? ' ."'<•'•'
Class 2
37)
38)
39)
Reasons for Success. What are the key contributing factors to your successful program?
IU Non-compliance. What steps have taken to achieve an improved level of IU
complaince? What methods have you found, effective in changing a noncompliant IU into
a compliant one?
Suggestions for Non-compliers. What are the first steps a POTW program should take to
improve its noncompliance status? What are the first steps a POTW program should take
to improve its IUs' noncompliance status? v
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Attachment 2:
SUMMARY OF ISSUES AND RECOMMENDATIONS BY PROGRAM AREA
; Following the format-of the interview guidance (Attachment 1), this section provides a
summary overview of the majo'r issues brought out by pretreatment staff during the course of our
site-visits and interviews. Each issue is followed by a summary of the recommendations made by
program staff and EPA personnel as possible solutions. These recommendations represent a listing
of suggestions; they have not been analyzed for effectiveness. With" this caveat in mind, it is also
important to note that many of the suggestions are in current use by one or more of the programs
visited, and that the programs often felt the approaches were working.
Identifying lUs
1. Identification of unpermitted dischargers has been a challenge for some POTWs.
- • - •, ~\ • . '•' : ••'•'• . ' • ' • .' ' 'i
•. Use multiple sources of information to identify these firms. Some of the
sources that programs relied upon included: telephone yellow pages, changes
„ in water consumption, sitevisits, construction permits, applications for water
or sewer hookups, inquiries to the local Chamber of Commerce, and
hazardous materials filings with fire departments. ', -
• Rely on regulated competitors to act as a powerful source of information.
Firms do not want to be unfairly disadvantaged by businesses that evade
.water treatment regulations: , . '..'.'•
' • Employ uhannounced inspections and "drive bys" of industrial areas to
- identify new dischargers.
Permitting lUs
1. Inspection of minor industrial users (MIUs) increases workload with small or
insignificant environmental benefits.
• Relax regulations of smaller categorical users who discharge such low levels
. of regulated constituents that they have no effect on the POTW meeting^ local
limits. -,. /- ... • ;. ' _.'" ' . ,
• Reduce frequency of MIU inspection.
2-1
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• Coordinate with local industries'and trade associations to implement best
1 management practices on industries with relatively small discharges instead
of permits.
• Require zero discharge from certain types of industries (e.g. dry cleaners).
Setting local limits has been difficult for smaller POTWs to do.
• Hire consultants to aid in this challenge.
• Work with other POTWs to share successful strategies for establishing
technically-based local limits.
Pollution Prevention (P2)
1. Economic benefits of installing P2 equipment and processes were often not known.
• Demonstrate the economic benefits of pollution prevention through pilot
projects.
• Prepare information on costs of service and influent constituents (i.e., better
cost accounting) in order to adjust fees accordingly. This will .give
dischargers price signals that help them identify, where to invest in waste
minimization or pretreatment equipment.
2. Inspectors are not always trained to identify promising pollution prevention
opportunities.
• Have inspectors shadow an experienced staff person to learn how to identify
P2 opportunities. , ' ' • " .
' ,u ' ' • " • ' • ' • • 'r ' ' ' •'. -
• Create a handbook that highlights P2 prospects.
• Provide inspectors with pollution prevention materials to distribute.
3. There are not enough industry-specific inspector training guides available for those
interested in expanding their P2 efforts,
• Implement better sharing of existing P2 documents, including materials
developed in other languages (to target industries with large, immigrant
populations) and at conferences.
2-2
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>• , • Develop industry-specific information on P2 options obtainable via PIPES.
• Establish a phone list of specialty contacts who are willing to field questions
about particular P2 issues.
i. . . - ' • , - *',",..' -". '
• .Work through local trade associations to demonstrate the value of P2. '".••••
• Provide educational courses on waste minimization* opportunities-.
4. There is an existing level of concern among POTWs that P2 or pollution control
equipment (PCE) will not perform as required or as advertised.
• , Provide facilities with actual examples of industries that have successfully
benefitted from installing the equipment. ,
• Compile performance data on equipment and technologies.
• • - ' - .-.. * • ''"'.. '"' • : • '. '•"" • '- • • ; / -'' ,"";- •"'' ;'
EVALUATING THE PRETREATMENT PROGRAM ~
Controlling Discharges/Sample Strategy
' , ' f r • ' ' ' ' ', ''.•'•'• ' - .
1. Chemical discharges are not always detected in advance, leaving treatment process
vulnerable to potential upsets.
•' Understand IU processes to ensure that processes are "under control." If
violations occur they can be quickly detected and corrected.
''"'.' V " . .
• Install sensors on inflow pipes or conduct: regular trunkline/lift station
samphng to alert a facility in advance if they should divert flow to protect the
treatment plant from upsets. ,
• Use dedicated samplers to make testing SIUs easier to do and to reduce the v
ability of the IU to manipulate flows when an inspector arrives.
• Increase use,of unannounced sampling to confirm KJs are not altering
\ production parameters to hide non-compliance.
• Distribute test kits to public works personnel to facilitate rapid sampling of
unknown discharge seen or smelled in the sewer.
-------
• '. Create an Interjurisdictional Agreement (IJA) that gives POTWs direct
enforcement or monitoring control over remote industries. This would work
to ensure that pretreatment programs have adequate control over their
dischargers.
2. Regulation of indirect dischargers only does not necessarily allow the POTW to protect
quality of their overall receiving water.
• Give pretreatment. program responsibility for the entire receiving water rather
than just the plant outfall.
" ' ' ' ', • ' , ', ' ' ''' ' •' '' ' ' • i - " , , " • '' •' ' • '• " ' ' ' ' "v• \ .';, '"
I, '" „ , ' ' • ,',''' i '. . : I • 1 ' ', , •; ' ; 'i1 n •,''.'
• Target direct dischargers as well as indirect, and work with them to
implement pretreatment programs.
3. lUs do not always feel comfortable talking to POTWs about a problem that they are
experiencing.
• Initiate an industry advisory council approach to act as a forum to educate
industry about regulations and to build trust over the long-term:
• Establish a close working inspector/lU relationship to promote open lines of
communication.
• Treat lUs fairly in regards to self-reporting and insignificant violations.
• Maintain frequent contact with lUs even when there is not a pending
problem.
Many POTWs use contract laboratories that provide poor quality analysis .and
inadequate service. ,
• Develop guidance to assist-pretreatment programs and lUs in choosing a
qualified lab.
• Require a copy of the lab's Standard Operating Procedures (SOP) manual,
and visit the. lab. If the lab will not send an SOP, or the pretreatment
manager is not allowed to observe the operations unannounced, disqualify the
lab from consideration.
• Require that the lab meet a pre-determined .turn around time. Upon failure
to meet this tune frame, disqualify them.
2-4
-------
5.
• Develop laboratory certification, or increase the. frequency of EPA quality
control audits,, to increase lab quality. . , " .
• Substitute biological indicators for some chemical lab tests, where possible,
such as by testing whole effluent toxicity. This wiU'help identify any
synergistic impacts of discharges. ,
Several top performing pretreatment programs express frustration at some of the
federal requirements. .
• Allow top-performingpretreatment programs greater flexibility in deploying
available resources to areas of me program mat me facility feels will ha
greatest environmental benefits. ' .
Inspection and Enforcement Strategy .
1. Difficult to balance enforcement and education; good working relationship is needed
between pretreatment program and IU to identify and solve discharge problems.
• Maintain the education and enforcement balance. Incorporate education into
the strategy while preserving the enforcement component of theinspection.
', — Provide.general information on how to address complianceTissues by ,
way of education, rather than making specific recommendations that
could cause problems later on if they don't work.
,~: m addition to.the typical inspection, add a new educational
component each visit, by choosing a different target area to discuss
. ' " in detail with the IU. ; ' . , "
— .Invite a third parry to take over frompretreatment staff (e.g., POTWs
legal staff) as soon as there is-a problem, so as not to contaminate the
relationship between TUs arid pretreatment personnel.
-' ' - " " . • " }•'•',-• ' •" ' -
,• Communicate program goals to the lUs.
' • Focus attention on why an IU was out of compliance and not on determining
whether they were or not.
• Send the same inspector for a number of years to provide continuity and
specialized knowledge. ~ ,
» Rotate inspectors every few years to avoid cooption and to allow fresh eyes
to spot trouble areas. " ^
' '' i • • > *" '. • . -
"•,-'.-' • ••• .'V •' -•• ;•-• 2-5^' .•-••' •- % , . '•-•.•••;
-------
• Streamline inspections by multiple oversight agencies to reduce the
regulatory burden on industries.
2. Inspections tend to capture facilities when they are on their "best behavior".
• Conduct unscheduled inspections to allow inspectors to see how the facility
is run on an average day.
3. Political pressures and the-threat that industry might move out of town sometimes
make it difficult for POTWs to enforce against Ills.
• Demonstrate how a strong pretreatment program is not a threat to business.
• Build a solid working relationship with the political entity to allow for
continued progress over a period of many years.
• Bring in help from the state or region.
• Use publicity to leverage recalcitrant national companies. v
• Levy fines that are refundable upon. RJs implementing specified
improvements in the appointed time frame.
• Provide POTW some leeway by creating a hierarchy "of enforcement
strategies of gradually increasing severity.
EMPLOYEE ISSUES, EDUCATION/TRAINING ACTIVITIES AND INITIATIVES
Staff Issues
1. POTWs are faced with a high rate of staff turnover.
• Expand jobs to keep them both challenging and interesting, by providing
opportunities for cross-training development to learn other's roles.
. • ' Implement a formal tier job classification system to eliminate dead-end jobs,
move employees to the highest level over time, and increase expertise.
• Develop an awards system to maintain motivation.
• "Distribute "grunt" tasks equally among all tiers of employees.
2-6
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Training
New coordinators often do not know "where to begin" in running a pretreatmerit
program. -' ".;. --"-.'' \ . .-- •, '-•-' • •-.-. ...- -.' . •-••' \ •/;'. -
• Provide a simple "ramp up" course that helps them prioritize training and,
. navigate the many available guidance documents. ' -
• Develop a new employee pretreatment program orientation package that
would include the history of the pretreatment program, job responsibilities,
and the required reports and plans. .
• Develop strategies to assist small pretreatment programs. .
. • . •- • . \- . • "_••--_
It is difficult for POTWs to stay up-to-date with current regulations.
• Create a non-legalistic guide of the regulations hi a timely manner, to aid in
compliance. .
• . Create working relationship wirn surrounding universities and use students
to leverage limited staff and update routine information.
• Obtain regulatory changes from WEF and on-line sources.
• Work with surrounding POTWs to leverage useful problem solving
resources.
• Seek out topical seminars that travel to the plants.
Time and budget constraints do not allow POTWs to take advantage of training
opportunities and tools that would make their jobs easier and their programs more
effective.
• Provide tools that can be distributed locally.
, ,•-'. — • Initiate regional pretreatment meetings.
-^ Develop, exchange programs for pretreatment managers and staff that
allow them to visit various sites. .
Obtaui or develop training videos that use expert inspectors to help
. train staff at smaller programs both hi general techniques and how to. -
evaluate with new industries. ^
-- /Hold in-house training seminars produced by larger POTWs.
2-7:, '
-------
• Use state and federal water personnel as informational resources.
- " , ; • • , ., " ' : ' • 'i ' ' .''•. , ' •, • •'. '• . . ' ' • .•'.•,' ,•,'"•,
-------
2. Geographic Information Systems offer much to pretreatment but are slow to evolve.
„• .'• Learn how GIS could help pretreatment programs. : • .
• Establish links with existing GIS groups in municipality or other parts of the
WWTP to collaborate and coordinate information gathering and system
design. , .
* - • • ' ' • -^
- ' '-".">. ' ". " • . ' , . *.
PRETREATMENT RESOURCES AND COST ACCOUNTING
Budget ;'.'.,
1. Some programs lack an independent budget for pretreatment staff and are not made
aware of the resources that they have at their disposal.
• Work closely with the utility manager to create a budget system that
communicates available funds to pretreatment staff and provides incentives
for improving program efficiency.
• Create a model budgeting system (EPA). ' .'
2. Without capital budgeting, POTWs do not develop a normalized estimate of their cost
of providing service. *
• Establish a capital budget using debt issues or sinking funds to finance a
capital investment. . ( .
, • All capital, including computer systems development,; shouldbe financed this
• •, ' way. • • - .' . " ' ' '""'''.'.- • ' •--'•''.- ••
3. Programs do not have any indicators to measure their program efficiency against
others. v
• Develop and use define^ measurements (e.g., operating ratios)'to enable the
• program to compare its facility to others around the country.
2-9
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Cost Accounting
. 1.
2.
3.
POTWs are seldom aware of the financial impact that particular discharges, or
particular discharging industries, have on their system. For example, contamination
of sludge and treated effluent, such as with metals or salt, can preclude its reuse as a
soil amendment or as irrigation water.
; ' '.'"•„ '' ,..''..•' .! "•''• '' ./A,'''':,1'. ''•• : , ;,;•'•( •.'''' '.'• '• • •'•.'• ;" " ' ':/ '"•'•• '':« >t'
• Work with city officials or outside consultants to set up a strong cost
accounting and cost recovery program to ensure that IUs are not being
undercharged.
• Evaluate how particular industries or dischargers affect plant costs. Use this
information to set charges or to identify areas for POTW investment in
pretreatment.
I. " ' '...''• ! -.• " ' • •• ',' " ' • "', ',;* ' , ' ' ',. '•' -..'.'' , . _ . ' • : •' ••' '':
• Charge IUs the: actual amount the POTW incurs to provide service, in order
to eliminate any cross subsidy and to encourage P2.
The billing of inspections and associated lab tests is often difficult to track.
• i"" * » • :, « ' , . • • ' • f • • ' ' s • , .1, • i.1 i , »•..,, ., i i.
• Integrate these components into a broader cost accounting system..
11 ., .''.''' •''/!,.:'.** ' . ' '
• Hire a firm to take over billing processes.
Expansion of sewer lines is subsidized by the POtW or by the county, understating cost
of service and reducing the incentive to find alternative treatment
• Be sure line .expansions are included in a cost accounting system.
Innovative User Fees .
1. Facilities face the need to expand capacity without the financial means to do so.
• • Require developers to purchase access to sewers before beginning their
projects. , . .
• Use cost accounting system to help identify ways to use existing capacity
more efficiently.
2-10
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1)
Attachment 3:
SUMMARY OF TOP-RANKED POTW PROJECTS
'Guidance to the Guidance" for pretreatment program coordinators
Purpose: To provide a simple "roadmap" for a new pretreatment coordinator about what
they are responsible for, where they can get a quick overview of each area of responsibility, and
respurces they can use for upgrading their knowledge base, the project would produce:
• A general overview of the components of a pretreatment program and the
responsibilities of the coordinator. ' .
• Background on the requirements for each aspect pf the program. •••__. •
» Suggested references for increased understanding of any one part of the
program. This would refer staff to specific chapters within a broader guidance
when possible, to reduce the need to review peripheral information. .
' ~ " • . . , •_• ' : _. - _ - ' ' v
Need: Pretreatment coordinators must have an extremely wide range of knowledge, from
state and federal regulations to laboratory and sampling issues to a variety of industrial
processes. Many coordinators, especially at smaller programs, faced a difficult situation when
starting their job. They lacked trained colleagues to transfer knowledge on how the program
should be run, yet faced many requirements as soon as they took the job.
Progress to Date:
• Developed outline of guidance Components; /"
„• Identified some programs with expertise in the area of staff training, and
others with an interest in using such a. document.
Next Steps: EPA has prepared an outline of what this document would look like
(attached). Moving the project forward requires:
• Work group approval of preparing the guidance. ; .
• . Subcommittee endorsement. , '.;.... ;
' ' . '- ' . ' :' ' [ 3-1: •'•' '• • . ''' :. ' ' •' '
-------
,',,(i1!';1:! «{ , SUM"
• Identification of partners: O W; CC; AMS A ,(to work with programs that have
already developed similar products, such as Orange County, CA); and one or
two regions (to work with regional staff and local programs that would be
using the document).
• timeline: The workgroup expects this project to take approximately 6 months
to complete.
2) Training Videos
Purpose: To bring targeted expertise to remote programs without travel budgets and to
help IUs improve their pretreatment systems by giving them insights into what a pretreatment
inspector is looking for during a site visit.
Need: Many of the programs visited expressed a strong interest in visual training
materials. They felt that a video would educate personnelwith different learning styles better
than written material, and that many of the subtleties associated with an inspection .(e.g.,
professional appearance, tone of questioning, eye contact, etc.) could be demonstrated. Since a
video could be shipped to small, remote programs, this medium would provide a low-cost but
useful learning mechanism.
Progress to Date:
• The workgroup has identified its preferences for the first three videos: (1)
'"* program basics, including how a strong pretreatment program helps business;
(2) sampling; (3) conducting an inspection. ,
• A couple of potential longer-term sources of funding have been identified
(primarily the CWA grant program).
• Based on the near universal support for his written guidance materials, Ken
Kerri (of California State University at Sacramento) has been identified as the
first choice to produce the;videos..
•3-2
-------
Next Steps: •'.''.'",••:• /. . • • : V •.':".' •'. ' . ' . •
• Workgroup approval for moving forward; Subcommittee endorsement
• Additional research on funding mechanism:
• . - ' •.- "- ' '"' ~ r'. * '•
- CWAgrants. ':'-..,'.."" '
— Ken Kerri interest & experience with videos.
- Check existing projects of National Enforcement Training .
Institute. ,
' ^ —: Work out funding mechanism for first video. , •' .
• Identify partners: ^ , .
-- OW, pC, AMSA, NETI
3) Upgrades to PIPES on-line information system
Purpose: Develop PIPES into the primary conduit for general information on
pretreatment for the nation. Provide user-friendly repository for past guidances, and a point for
communication and sharing of solutions among pfetreatment staff across the country.
Need:
• Most pretreatment programs faced a handM of similar problems:,
Couldn't find the information they, needed to solve particular problems.
, —. Had difficulty obtaining copies of EPA's past guidances.
-- Often couldn't afford to travel to attend conferences or visit other
programs.
• PIPES, as an existing bulletin board system for water issues, is the natural
solution to disseminate knowledge across the nation and to develop into an
active community of informed users. ,
3-3
-------
Progress to Date:
Have identified major areas of PIPES upgrades from site visits:
Put old EPA guidance on the system.
-- Convert all system documents to universal PDF format.
Expand access to PIPES, make full WWW'site, and .make more
user friendly.
- Upload "plain English" updates and summaries of regulations of
concern.
Create a PIPES regional calendar, to which regions and states
could add activities.
Create additional content for the system, including information on
P2, changes facing pretreatment programs as their NPDES permits
are renewed, and compiling national SNC/NOV summaries to
increase leverage of POTWs over recalcitrant industries.
Next Steps:
": . " • ' ( ; ' ( ' ' '
• Identify budget and plans of current PIPES staff.
betVorkgroup and subcommittee approval to make PIPES a priority, and get ,
endorsement of various subtasks.
i, • ' • . «,',,. i • " ' ' V '' i ' ', ' <
identify partners and develop timeline for each subtask.
4) Pretreatment information systems transfer
Purpose- To identify and promote mechanisms that allow pretreatment programs to
share information system development costs with other POTWs and with other branches of their
own POTW; to demonstrate the financial and environmental benefits of good pretreatment
information systems. .
Need- Pretreatment programs face very similar challenges and regulatory requirements
across the country. Information management and pretreatment data systems play a critical role in
organizing the information the programs need to meet regulatory requirements and ensure their
POTWs meet their NPDES permits. Large programs have tended to develop unique data
systems, at a cost of hundreds of thousands of dollars each. Small programs have either written
their own simple (but limited) applications or used less-than-satisfactory commercial or EPA-
developed software packages. In both areas, programs expressed interest in .ways to improve
their systems at a Jower cost. ,
" ' ' . .' ' ' 3-4 •' ' ". ' "' '"
-------
Progress to Date:
Have begun background research on pretfeatment information systems.
Have identified programs that might be interested in participating in this
project _-, '
Next Steps:
Initiate discussion of strengths and weaknesses of existing systems and unmet
needs. ..'•;.
Work with one or two large programs on issues associated with selling or
giving away software to other POTWs, and on documenting the
environmental and financial benefits of good information systems.
Identify innovative mechanisms to encourage private sector provision of
pretreatment software.
5) Cost Accounting and Budgeting
Purpose: To demonstrate how improved cost accounting:and budgeting for pretreatment
can make the job of pretreatment coordinators easier, demonstrate the cost-effectiveness of
pretreatment programs, and provide important information to Ills about the most effective areas
to invest in pretreatment equipment or pollution prevention.
• "' , • v ' ' ' :' ' • • " " ''
Need: POTWs with approved pretreatment programs are required to have adequate
resources to implement the pretreatment program. There is a very strong link between resources
and funding of the program. Both dischargers and POTWs make decisions, in part, based on
costs. If the cost information they use in these decisions is wrong, they may underinvest m
pretreatment equipment, or in the pretreatment program overall. Most of the programs visited
had incomplete or inadequate cost accounting and budgeting.systems. In some cases, program
staff had no access to information on the pretreatment budget. In other cases, the pretreatment
staff had little information on how particular dischargers affected the overall cost of operating the
POTW. In both cases, staff did not have the information necessary to inform their management
about the various operational tradeoffs they faced in running the program. .
.3-5,
-------
Progress to Date:
• Have identified major categories of weakness in existing cost accounting and
budgeting systems. '
1 • Have identified a couple of promising case studies, although these programs
have not been approached yet to see if they are interested in participating.
Next Steps: . ' •, . . ". .'"'''..' •
• Identify target case studies to gauge their willingness to participate.
• Identify additional data that would be needed to conduct one in-depth study of .
cost accounting problems and one of budgeting problems.
• Develop format for case studies that would be useful both to EPA HQ/CSI and
to the case study participant in improving then: existing systems.
6) Choosing a Contract Laboratory
Purpose: To help pretreatment staff understand how to evaluate contract labs. Areas to
be covered include: the types of questions to ask, how to structure an RFP for lab services
evaluating a laboratory Standard Operating Procedures manual, and evaluating the decision of
when to use a contract laboratory rather than conduct testing in-house. The focus would be on
lab consumers (i.e., pretreatment programs), rather than on laboratory staff as has been done in
past EPA .guidance.
Need- Much of the effectiveness of a pretreatment program relies on sound analytical
data. Thus, choosing a laboratory capable of producing such results is critical. Since many of
these labs may also be used by lUs, and for sampling as well as analysis, many programs felt that
the choice of a lab was one of the most important in their program. POTWs with relatively
sophisticated lab assessment practices felt that many programs had little undersanding of how to
ensure they were getting good analytical services.
Progress to Date:
• Have identified POTWs that might be interested in serving as partners on this
project. . .
S--6
-------
NextSt.eps: . '' . • . ' . ••,.'. , •-.'"':, •".. ' .'"•. * • "
", ' ' -•.•-' ' • • •'•/'.-.' • -
• 'Discussion of why this is important at the JulyF AC A meeting.
• Workgroup and subcommittee approval of project going forward.
• Identification of additional partners (considering OC, Elkhart, HRSD,-and
'. '•' OWOM&OST). > v
• Coordination with related EPA work: , ', .'/
— OC work on good lab practices.
- OST Engineering and Analysis work. ,
• Decision on whether to integrate with a lab certification program or to-.., ,
consider separately.. ~ V.
• Evaluation of issues associated with POTWs preparing a list of acceptable
contract labs. , ,
\ . - '•'-.- !-•'•' ' ". .-...'•" - .. . '
7) Increased regulatory flexibUity for top performers
Purpose: To allow top-performing pretreatment programs greater, flexibility in
deploying available resources to areas of their program that they think will have the greatest
environmental benefits. .
Need: Many of the top performing pretreatment programs expressed frustration at soine
of the federal requirements they had to follow. An example is the requirement that they monitor
and inspect all categorical users, no matter how small, m some areas, program coordinators
pointed out that these small CIUs had very little impact on their systems (i.e., POTW
performance, effluent and sludge quality), yet took up a disproportionate amount of staff time to
oversee. A number of other examples were also mentioned.
Progress to Date:
EPA Office of Water, Permits Division has started work on a plan for streamlinrng the
National Pretreatment Regulations. Issue papers have been distributed to approximately 80
identified stakeholders.
3-7
-------
Next Steps:
• Develop a plan to educate POTWs about where flexibility exists in the current
regulations that they have not taken advantage of.
1 " f , , ' • , ' "„,",' _ ' ''''.'"
• Provide more, detailed information on the progress of regulatory revisions
now in -process, including which specific areas it- is . addressing, who is
involved, and the expected timeline for completion. Possibly bring in other
parties (e.g., AMS A) so they are aware of the progress being made.
" ,'•' - , ,"i •' . , • " , i ' , • ',•;''..'' "i ,;. • '•" '•! •; ' /•' ;• ' ''" ' y > '' '"''"'" '•'.;. ' •'" ' :^
• bevelop consensus on results-based performance measures that would allow
EPA to grant flexibility .to POTWs without a .risk of this flexibility
contributing to reduced environmental quality.
" ' " , '' ' •' ,'' , ' , ,,',"', ' ' *• ' ' ' ' ' ' ! ' ' , • ' , '•' • i '". ' ' 'I '
Abbreviated Summary of Other Projects Considered
Each of the projects described below were brought out during site visits with pretreatment
programs. Based on the priority rankings expressed by EPA staff or ongoing EPA initiatives,
they have been put on hold. .
if • "» .,„ • , , , - , ^ , • -
A) Inspection Streamlining .
To reduce the regulatory burden on industries, this project would have worked to
consolidate some of the many different inspections that a facility faces each year. Since
inspections occur across all media and at the federal, state, and local levels, this project would
have involved substantial cooperation with a range of government agencies.
B) Model Interjurisdictional Agreement
Many POTWs accept industrial discharge from Itfs in surrounding areas, but have no
direct enforcement or monitoring controls over these remote industries. This project would
create a model IJA that, if implemented, would ensure pretreatment programs had adequate
control over their dischargers. , .
EPA staff pointed out that EPA recently developed a model IJA, and.felt that this
adequately addressed the concerns mentioned by the programs.
.3-8
-------
C) Evaluating impact of new discharges on POTW
; New materials are constantly entering the marketplace; residuals often then enter the
POTW system. This project would develop an organized way of testing these materials to be
sure they didn't inhibit POTW functioning.
D) Place-based regulation of water quality
POTWs regulate only indirect dischargers, though direct dischargers can haye a
substantial impact on the quality of receiving waters into which the POTW discharges! This
project would compare the quality of receiving waters between regions that have locally-based
.regulatory control over the entire water-body with those that don't (i.e., most POTWs). ,
E) Information provision
A number of additional areas of .information provision were suggested, including
guidance on sludge and sampling, and PR materials for pretreatment overall. These were viewed
as lower priority than other projects. . .
3-9
-------
i'.!„:!!• '"/Mi!'!! '•' rfiiii' "i"1, '"•' ,
-------
Attachment 4:
SUMMARY OF CALIFORNIA POTW SITE VISITS, FEBRUARY 26 - MARCH 1,1996
SITES VISITED ,
East Bay Municipal Utility District
Union Sanitary District. . •
City of Esqondidojs Hale Avenue Resource Recovery. Facility . •
City of West Sacramento POTW
County Sanitation Districts of Orange County
Interview Team: Jim Casey, OPPE; Mamie Miller, OECA; Doug Koplow, ffic; Greg Arthur, EPA
Region 9 (for East Bay Municipal Utility District and Union Sanitary District only).
. •,, ' •-''•• ' ,.. - , , • ' . •" "' \
MOST CRITICAL FACTORS IN RUNNING A SUCCESSFUL PROGRAM
Every program evaluated during the C A trip has reduced metals loadings substantially during
the past 10 to 15 years. These reductions seem to have come both from pretreatment programs and
from changes in the industrial dischargers.1 Despite this commonality, however, there are important
distinctions between highly effective and less effective programs. Below are the pretreatment staffs
views on me critical faetorsmmaJdng a program successful. .
• staff Expertise. Programs with substantial in-house expertise regarding
pretreatment systems were much more successful: .
-- Better able to write permits and evaluate the adequacyof pretreatment
• systems proposed by the Industrial User (IU). One inspector noted
that "rejecting applications is art important power,but utility districts
must have the technical expertise to evaluate a permit application.
Many POTWs simply can't do this."
..,---. Better able to provide useM feedback to lUs during inspections about
technological options and management methods.- With the same
inspectors coming over a couple of years, they know what is going on
at the facility and can provide more effective oversight-
For example, one of the POTWs had 62-63 platers in the 1980s; it now has less than 40,.
V" "-'- ' '" . " . ..4-1 ' -'• "" ' .". '- ' '., ' .'••.' '• '
-------
Balancing enforcement and education during inspections. At effective
-POTWs, inspectors have a great deal of knowledge about pretreatment
systems and act as professional resources for-IUs. They are viewed by IUs
as a useful resource as well as an'enforcement mechanism.
Understanding IU processes. The effective programs focused on
understanding the treatment process at IUs and ensuring that their processes
are "under control."2 In this respect, violations, even if they occur, can be
quickly detected and corrected. • '
Proper local limits. Proper local limits helped to focus program resources
hi the areas most critical in protecting environmental health and meeting the
plant's KPI)ES permit requirements.
Good information on costs of service and influent constituents. This
" information is used to set fees that send the proper signals to dischargers
regarding where to invest in waste minimization or pretreatment equipment.
OPPORTUNITIES FOR TRANSFERRING SUCCESSES
• Staff Training and Retention
Ml, '', ^ ,^ ^ , |,l , " ^ ,, ^ , ,a , I ,, ^ ' , „, ^,,1
~ m-hoiise training seminars produced by the larger POTWs could be
opened to inspectors from surrounding regions.
Some of the combining of staff functions initiated by programs we
• visited can help smaller programs to retain staff despite a small
diversity of IUs (often associated with limited opportunity for on-the-
job professional development).
Training videos using expert inspectors could help train staff at
smaller programs in general techniques and how to deal with new
industries.
:' 2 According to Greg Arthur, an EPA Region 9 study compared IU compliance rates to installation
of BAT. It was found mat only 60 to 70 percent of the categorical IUs with BAT installed were able.
to achieve compliance rates better than 92 percent and 97 percent of them could only achieve
compliance rates of better than 67 percent. However, these rates far exceed the abilities of the
industries without BAT in place. The reason this does not show up clearly is that most CIUs with
standards based on BAT in good programs in CA have the BAT installed already which means the
violations that show up now are usually due to the inability to operate the treatment equipment.
' ' ,, 'I • , . •• • •, ' : -.-• '; •• , 4-2 : '. ' '' ''' ' •' '" ' ; "'': """
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Information Sharing
Information systems and programming solutions to common
problems could benefit many pretreatment programs.
Improved on-line access to training manuals and regulations of
concern could improve dissemination of existing materials.
Pollution prevention programs often develop similar materials. A
joint effort among POTWs could reduce the cost.
Generic permits could be developed and shared among POTWs.
~ Multiple POTWs have repeatedly used outside consultants to produce
information systems. , '
Cost Accounting and Charge Structures
Establishing a better understanding of how costs vary in response to
particular types of discharges can help the POTWs set better fees and
encourage investment in prerreatment equipment
Understanding cross-subsidies and pqtentially eliminating them could
help to encourage new controls in the most appropriate sectors.
MEETING DISCHARGE LIMITS
The purpose of pretreatment programs is to help the POTW meet the discharge requirements
under their NPDES permits. These limits drive the local limits set by the POTWs for lUs. Stringent
NPDES limits for particular constituents, generally translate to stringent local limits. For example,
copper discharges into the SF bay are such an issue of concern that the POTWs have had to expand
outreach into the residential sector in order to achieve the required control levels. Some interesting
NPDES-related issues: .-•_,-••
• Multiple POTWs may share a single NPDES permit and discharge point.For
example, several facilities are part of the East Bay Dischargers Authority:
— .Allocation of allowable limits among these POTWs has manyof the
same opportunities for market-based mechanisms aslare applicable to
IU discharges and POTW limits.
- In the case of East Bay Dischargers Authority, there is no effluent
trading now, although trading has been discussed.3
3 There are a number of factors that can make trading complicated. First, trading may be applied
to both point sources (PS) and nonpoint sources (NPS). NPS are complex to model, and the
allocation of reductions between PS and NPS is.currently done at the state rather than the federal
level. In addition, trading must be based on mass-loadings rather than concentration-based loadings,
complicating measurement somewhat.
4-3
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POTWs discharging to the ocean tended to have less difficulty meeting the
terms of their permits than those discharging into SF bay, because limits.
tended to be less stringent. , ,
'"' •' ' •. " • '.,',' •' •>' ' ' ' ,•',*:. -: ": ' . ' ;.,''' : , ',','•/• " • ; '• •'•' '", "•>•':>'
Setting local limits has been difficult for the smaller POTWs.
One of thetreatment works hired a consultant who originally.set the
local limits without scaling up from their industrial flow to account
for dilution. As a result, the limits were originally set far too low.4
— Another program did not have local limits until forced to develop
them under court order.
Mass limits encourage increased water recycling, though they are somewhat
more difficult to set and monitor than are concentration-based limits.
California POTWs use some form of mass-based limits).
Allocation of Allowable Discharges Among lUs
"'!i . •• ' '• : ,'•"-.'', ',"> •'' " ; • •. • , •.'".; , ' ,, ; ,""-Y" / ' "" •/'•' : ". •,•'''.•:.•. ••
• New Versus Old Sources. Newer sources within a discharge area sometimes
haye more stringent discharge restrictions than do older sources. This tends
' to occur because CIUs must meet both Federal and local limits. The
difference in standards for existing versus new sources varies, and is due to
me ability of me Federal government to impose a more rigorous level of BAT
on new industry. . For certain industries, such as platers, some of the
: industrial users we visited argued that these differences had substantial
competitive impacts, with, allowable concentrations up to an order of
magnitude different between similar plants.' '
• No Use of Marketable Permits. Allowable discharges were allocated
among lUs by fiat. Although the flows are centralized within a single
POTW, none had used market-based mechanisms to allocate allowable
\ discharges based on the marginal costs of control at the plant.5
4 However, once these new limits were set, their program manager calculated mass-based limits
pa his own. Despite their ability to encourage water conservation, mass-based limits are more
difficult to set and enforce than concentration-based limits. As a result, there are relatively few
PC)TWs that use them. .
5 EPA came-out with some emissions trading guidance in January 1996 that may make trading
more common. ,
•" •' , '• • ' •' •••'':•••. 4-4 • ' ' . , •" '
j • tys, ,••: .,•,•
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IDENTIFYING INDUSTRIAL USERS
An important aspect of every pretreatment program is the. ability to identify new IUs, All
of the POTWs we visited felt that there were very few IUs of which ,they were .not aware. They
described a fairly complex process to identify new dischargers. This process was similar across
POTWS. " "' • ." -.'..; ; . •.," ~ - ' ;. ' . ••' *:., -: ••.'. -! -
• Literature Reviews. Yellow pages and business licenses were reviewed, as
well as any new construction permits or sewer modification permits.
• Information from Other Municipal Departments. Pretreatment staff
-. , networked with other municipal functions, such as local fire departments and
hazardous materials regulators for leads on industries to target. Similar links
were often maintained with surrounding communities, for advance
information of firms seeking to move in. ;
• Site Visits. Unannounced inspections of industrial areas were employe
•...".' many pretreatment programs to identify new dischargers. This approach is
" especially important in warehouses, where subtenants may share a general
. water meter and discharge pipe.
• Competitor Reporting. A couple of POTWs mentioned that regulated ..
competitors have been a powerful source of information, as firms do notwant
to be unfairly disadvantaged by businesses that do notincur the proper waste
water treatment costs. ..'•>- .••.'•
• Analysis of Water Data. Where POTWs have access to water consumption
data, this has proven to be a valuable targeting tool for identifying IUs. High
water consumption or sudden changes in consumption patterns are an
important indicator. Most of the POTWs require a periodic water mass
balance, where an .industrial user must reconcile water inflows and
discharges. This exercise provides the pretreatment program with important ,
baseline data on IU production processes, as well as evaporative losses and
non-production uses such as landscaping. - -
According to one of the larger POTWs, field-checking remains extremely important because their
IU turnover can be as high as 10 to 20 percent per year. Despite the feeling that most IUs had been
identified, some of the POTWs did experience fairly high levels of discharges that were unaccounted
for. While not large enough to send the POTW out of compliance with their NPDES permits, the
discharges do suggest that there may be pockets of illegal dischargers.
4-5
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"', if: '
SAMPLING AND INSPECTION STRATEGY
Inspection Strategy
A number of goals associated with the pretreatment inspection programs were mentioned by
multiple interviewees:
'i . ' ', '','','
• The best programs used inspections as a way to communicate program goals
to their lUs and to educate them regarding pretreatment options.
_. TO provide continuity and specialized knowledge, the same inspector
will generally visit the same sites for a number of years, this helps
j = them to understand the site and quickly identify changes, although
POTWs must rotate staff eventually to minimize the risk of cooption.
One of the smaller POTWs said that their inspectors pick a target area
ahead of time to discuss in detail with the IU. m this respect, the
inspections convey new information at each visit. \
Balancing, education and enforcement objectives of the inspection was not
easy:' ' • ' •.•••,•.- ':''';,'
Universally, while inspectors would provide general information
about available technology or waste water treatment operations
management, they would not make any specific recommendations.
Specific recommendations, if they didn't end up working, could be
. very problematic'for the POTW.
Larger POTWs rotated staff every 1 1/2 to 3 years, to minimize the
" likelihood of inspectors being coopted. The rotation represents a
balance between site-specific knowledge and inspector independence.
Inspectors, liked staying on the same cases for a few years because
they were able to see improvements in plant operations attributable
to their work.
--, Many of the inspectors tried to have some interactions with lUs mat
were not enforcement-related, such as sharing information. This
helped them to be seen as a conduit of possible solutions rather than
simply an enforcement agent.
Inspection and Sampling Frequency
, , " , , | " , ' ' • ". ' ".',...', ', " ' •„ , ' ' ,:
While the exact number of inspections per year varied somewhat across POTWs, the
rninimum for lUs tended to be two per year, with one being announced and one unannounced. The
announced inspection helped the inspectors identify how well the systems could perform, and
4-6
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provided data used to. set .'local..limits.6-'. Larger 'IUs tend to have a greater required sampling
frequency For .example, one of the larger POTWs requires sampling at SIUs of 8 to 12 times per
year and four times per year at IUs. Self-monitoring (which does not always heed to be sent to a
certified lab) is done even more frequently;. .
Within these frequency targets, many of the programs give the inspectors-wide latitude in
scheduling specific inspections. One POTW, for example, feels that inspectors need to be free to
spend as long as necessary at a particular site to get the information they need. Flexibility in
scheduling gives them this freedom. -.,'.-••'"
Due to the high workload and relatively lowreductions in loads/from minor industrial users
(MlUs), most of me programs have tried an alternative to the inspection and sampling routine
followed for larger industries. Among the options utilized:
*> ' , •— ' • •' •• i V '•''-.''• •
• Reduced inspection frequency. MIUs are'.frequently inspected only once
per year, if at all; - ,
~ . . . '• - • • • . ' • '.'..'_•
• Prohibit discharges. For industries where zero discharge is technically
feasible, some of the POTWs have pressured these firms to stop discharging;
entirely. The approach often employed is dual track permitting: simple for
firms agreeing to zero discharge, more-complicatedand expensive for firms y
opting for traditional oversight.
• Best management practices and standardized permits. Industries with
relatively small discharges and similar characteristics across a large number
of small shops have been dealt wim in some cases using a best management
practice apprpach rather than through individualized permits with chemical-
;\specific limits. One POTW has applied such an approach to radiator shops
and automotive repair shops with machine shops. Another has used the
. approach for restaurants and dentist offices.7
Many of the MIU strategies require careful .coordination with local industries and trade-associations.
6 One POTW noted that if the IU ran operations hi order to minimize pollutant loadings during
the.announced inspection, this would hurt them in the long-run because their local limits would be
set at a lower overall discharge level.
7 Prior to shifting to this approach, one of the sites had nearly 200 permitted facilities, and not
enough inspectors to go around. Once local limits were developed, the POTW could identify
problem areasi and eliminate unnecessary permittees. -> -.
'." ' . . ••_ , ' ;-. .'• . 4.7 • •:..;;- .";••..'•;•: .'.
-------
One POTW was hoping to extend prohibitions on oil and grease discharges from restaurants,
rather than having specific limits. Under 40 CFR 403.5b, petroleum oil and nonbiodegradable
cutting oil are prohibited from being introduced into a POTW. Testing for these constituents is
expensive and requires the use of Freon and hexane, posing both environmental and worker safety
issues. Furthermore, the oil and grease is a problem for the collection system rather than for the
treatment plant. A blanket prohibition would simplify inspections and avoid the need for sampling
and testing. ,
Slug Protection and ITJ Process Controls.
'/ • . , i - .• i.
To protect their treatment process from upsets caused by chemical discharges, pretreatment
staff have worked to improve advance detection of incoming chemicals, accelerate their ability to
trace such discharges back to their source, and work with industrial users to reduce the likelihood
of surprise discharges.
Advance Detection of Incoming Chemicals and Tracing Discharges Back to their Source
• ' Remote Sensors. In one of the plants a series of sensors were installed on
theii'inflow pipes. These automatically relay information back to the central
offices, providing advance warning of impending slugs. The POTW can then
I divert flow if necessary, to protect the treatment plant from upsets.
, „,, , _ , ,,^ , ^ ,„, i _ ^ i, i;, . t ! ' ' ' " ", "• , j '
• Unannounced Sampling. Most of the plants we visited supplement self-
monitoring and site-sampling with unannounced trunkline sampling. Thus,
illegal discharge levels can be detected. These tests have been useful on
many occasions. For example, one of the POTWs discovered that one of its
"model" industrial users, nominated for a pretreatment award, was illegally
••'."' .discharging wastes on a regular basis.
Ensuring a Process is "In Control"
An industrial process that is "in control" is well understood and behaves predictably. In the
same way that a plant works to ensure its products have no defects, process controls from a
pretreatment perspective involve ensuring that discharges are predictable and within compliance.
If exceedances do occur, the IU should have a process to quickly detect the problem and correct it.
Pretreatment staff use inspections to ensure that adequate equipment is in place, and use monitoring
and self-monitoring requirements to force the IU to gather information on how well its pretreatment
jj"fl' •'-.••• • .'.-., i • •, • •• i • , • .• • , • ....... ,•.... ,*• _ ... ..
process is working.
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The views expressed by staff on'self-nionitoring'are particularly interesting. All of the
POTWs require Ills to self-monitor and. supplement less-frequent POTW site-visits with self-
monitored data. Across-the-board, POTWs viewed self-reported data as less accurate than POTW
sampling events. . .
• RJs would generally, choose a time to take samples that would be most
beneficial to their meeting effluent limits. In addition, contract labs would
do what was possible-to help their clients.
• The sampling accuracy of these tests varies by constituents. One of the
POTWs has found oil and grease results to have the largest discrepancies
between POTW tests and self-reporting: In addition, contract labs often
conduct metals tests without using low enough detection limits. *
• POTWs viewed self-reported data as information for the IU to use to
understand their production process and waste water treatment system, rather
- than as useful for enforcement. It is a veryuseful tool for process control, but
.a relatively poor tool for enforcement. The implication of this viewpoint for
CSI is that a shift to total reliance on self-reported data, even for top tier
perfonners, may not provide an adequate oversight mechanism. •
Substituting Biological Indicators for Some Laboratory Tests
Many of the programs we visited used indicator species to test for effluent purity. These
organisms are sensitive to a wide variety of water quality disruptions, and therefore provide a useful
general indicator of treatment efficacy." One of the smaller POTWs does not conduct metals analyses
in-house. As a result, they seldom test influent for metals, but rely instead on disruptions to plant
microbes to signal influent problems. While these approaches may provide a cost-effective way to
detect problems, strong analytical capabilities are also needed so that problem constituents can be
quickly identified if a biological indicator should die.
ENFORCEMENT STRATEGY
Successful.programs echoed a theme already identified in the inspection strategy section
above: focus on the industrial process rattier than a specific incident. The enforcement components
presented below support this view of compliance assurance.
4-9
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Information Flow to POTW. At one POTW, the program manager wanted
to create an atmosphere of cooperation with the lUs to solve discharge
problems; to have IUs -focus on solving the problem rather than being fearful
of going to jail, this was echoed by another POTW, again focusing on being
contacted when there was a problem so the pretreatment staff could help the
IU solve it. ''",''" ", • , ,'',,,, , •
Minor violations, especially if they don't cause any problems for the
POTW meeting local limits or plant upsets, are met with relatively
low economic penalties, but fraud and lying to the POTW are.rhet
with criminal action.
The biggest problem they have faced with IU noncompliance is the
: use of unqualified people to operate the treatment equipment. At
rnost POTWs visited, staff felt that the IUs did have pretreatment
Equipment installed.
Focus on Why Out of Compliance. The effective, programs were not
interested in the simple question of whether an IU was out of compliance, but
rather on determining why such non-compliance had occurred. One of the
larger POTWs tries to tailor its requirements on IUs to help them better
characterize their waste streams.
Severity and Frequency of Violation. One of the smaller programs felt that
the severity and frequency of violations were important components of
determining an appropriate enforcement response.
,*»»
Most of the programs had a hierarchy of enforcement strategies of gradually increasing
severity. These hierarchies could be quite complicated, although all of them spanned a range from
a simple letter to criminal prosecution. Smaller programs seemed less willing to take significant
enforcement actions, especially if the non-compliance was not causing NPDES violations. One of
the programs used program engineers, rather than inspectors, to pursue enforcement activities as a
way to somewhat protect the inspector's role as a source of solutions for the IU. Where enforcement
actions forced the POTW to incur additional sampling and analysis costs, these costs were generally
charged back to the IU if a violation was found. Whether the additional charges were passed on to
the IU if violations were not found varied by POTW.
POLLUTION PREVENTION
Pollution prevention programs were one area where activities varied significantly between
large and small POTWs. Most of the large POTWs had well-developed pollution prevention
programs, consisting primarily of information sharing, case studies, outreach, and training. Only
4-10
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one program had financial incentives in place to encourage IU investment in pollution prevention
equipment, although several references were made to state-level programs that ostensibly encouraged
such investments.8 This program is financed through budget savings that the pretreatment program
is allowed to retain. The loan subsidy is open to any industry, even large sophisticated ones that,
have regular access to capital markets. Nonetheless, there have not been many applicants. .Staff
believe this is due to the fact that so many of the IUs are already., in compliance.
POTWs have been innovative in linking pollution prevention to their efforts to remove minor
industrial users from the standard permitting process, Efforts have included developing education
materials in foreign languages and working through local trade associations. Some have even
developed educational courses. For example, one of the programs has taught a course on waste
minimization opportunities for metal platers. This course was financed through a settlement with
an IU for discharge violations. Other important findings:
• Smaller programs discuss pollution prevention as an area they would like to
expand into, but feel their largest benefits in the short-term lie in improving,,
their control over wastewater treatment operations both at the POTW and at
••' ' -• - ... IUs. ,'•'.,•' .-...-: ' . -.''.. J ".•.,'-'''". ; •/.'•••' ' ' .
• It is our observation that even the larger programs have done little rigorous
analysis to evaluate the cost-effectiveness of their pollution prevention
- . activities.
** •"" ' ' -- *• • - r'
' • In addition, there appears to be substantial overlap between the pollution
prevention'materials developed by different POTWs. Combined efforts may.
be able to improve.the efficiency of some of these operations.
EMPLOYEE ISSUES
In-house expertise to write and review permits and conduct inspections was identified as an
extremely important component of a successful pretreatment program. To maintain and develop in-
house expertise, staff retention and training are important. Staff retention and training are continual
challenges even for the larger programs. It is especially difficult for the smaller, municipally-run
programs where pay scales can be low.
8 In California, this is primarily the CALCAP program that subsidizes loans to certain industries.
In practice, the program has not had much success in targeting pollution prevention investments over
pollution control equipment or even general.capital. "• ,
4-11
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Nonetheless, the best programs tend to have high staff retention, excited and motivated
people, and many more job candidates from outside the system than there are new openings. The
struggling programs have had a more difficult time attracting and retaining. staff. Some useful
themes came out across all facilities:
111 | !| ' ' ' • :', ,j. .1 ;• • \ : • • " " •:,?• .'.''•"'' " ' •' ' ' . . ': , ': • '" i'1 )*. ' '•' .•
'• •. .' • '"'-1 ..',.'•: i1 , • ., ' _' -t ' ' .' ' ' " " "
• Cross-Training. Training staff in multiple disciplines was viewed as
important by many of the POTWs, both to improve the decisions that field
staff make and to help wim staff retention by keeping jobs challenging and
" interesting. A major goal of one training program, for example, is to get the
staff to see the cross-media and cross-program, impacts of their activities.
• -,- Plant Operations and Pretreatment. For many of the programs we
. visited, pretreatmeht staff was fairly distinct from treatment plant
staff. However, pretreatment staff that did have plant operations
experience felt that this experience was extremely beneficial because
it allowed them to see the "big picture" regarding IU practices and
overall plant operations.
Alternate Staffing. One of the programs has developed an
innovative program to upgrade the skills .of its staff and has
established a formal three-tier job classification system (entry,
journey, and expert) to accomplish this end. The goal was to
. eliminate dead-end jobs and to move everybody to the highest level
over time. The system has improved staff retention and expertise.
Although staff will become more expensive over time (as more and
more people reach the upper levels), program managers were
confident that the,improved expertise would be well worth it. Joint
training between pretreatment and stormwater staff has greatly
. increased cooperation between the,two divisions.
— . Permitting and Enforcement. One program had problems in the
past because permits were written with a different perspective than
enforcement This caused.friction because; poorly written permits
caused problems for enforcement staff. To address this issue, they
combined the functions. The inspectors have a long-term relationship
with the firm's they inspect, conducting routine site visits and
inspections. Engineers, who also write the permits, get involved as
soon as there is any hint of enforcement action against an IU. This
division is helpful because the inspectors sometimes have a difficult
. time taking significant actions against the firms.
, ,» /i, . •, . ' , 4 i ,i.
' '' ' , ' " : f
• Sharing "Grunt" Work Evenly. Sampling is a task that most inspectors
1 don't like. Concentrating sampling tasks on entry-level employees has
created a "dead-end" job with high turnover. To address this problem, one
of the programs has required that sampling tasks be shared evenly by all
1 " • '' • ' 'ii , j ,'.'','•'. • ' i , ' " , '
': •. " . •/ . / ' •' • '4-12; •'"'." • ', '""; • ' ,: ••"; •"..
-------
levels of their pretreatment staff. Such a distribution keeps all staff current
-in sampling techniques as well as reducing the turnover at the entry level
positions. - . -,-.->.•-'
Expanding Jobs to Keep them Challenging. The greater the diversity of
the challenges facing a pretreatment employee, the more likely staff is to stay.
'•Larger POTWs, serving Ills in complex industries and a larger number of
users, have better staff retention than those with a required skill set that is not
challenging to master. For many inspectors, especially at small programs,
there is little opportunity for upward movement within the plant.9 Thus,
lateral movement, or movement to a larger POTW is quite common.
POTWs may combine functions, such as wastewater and stormwater
inspections. This reduces the inspector burden on private industry,
provides the inspectors with a broader exposure to the dischargers,
and improves the efficiency of government oversight.
For small POTWs, combining roles is a necessity; there simply isn't
a budget to have highly specialized staff positions. For example, the
: same staff at one POTW manage water, wastewater, and stormwater
functions. This variety does help to make the job more challenging
to inspectors.
EDUCATION/TRAININGACTIVITIES AND INITIATIVES
Pretreatment personnel stated that they found EPA manuals to be generally (although not
always) useful.10 However, they were often difficult to obtain, especially after they were no longer
printed. Program managers thought that putting the manuals on the Internet would be a valuable tool
and eliminate many of the problems associated with an inability to obtain the documents.11 Short.
of this, some of the older ones should be reprinted. Nearly every POTW was using at least one EPA,
manual that was over ten years old, stating that it continued to be of value, . . .
9 Even large programs may face similar problems. One of the large programs had a difficult time
retaining its-engineering staff after it had collected basic data on its lUs.
10 When asked for specific titles that were valuable, few were able to list them on the spot.
1 > Some manuals are available on the Point Source Infomiation Provisions and Exchange System
(PIPES) bulletin board system. However, EPA could convert manuals into a PDF format fairly
easily. This format allows -graphics and text to be combined in a visual image of the original. The
documents are accessible to all platforms (DOS, Apple, and UNIX) using a freely available reader
(Acrobat reader), and can be searched on-line or printed.
• '• -.-•••' 4-13 ' '•' ' .'..'''..-
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Sm'aher POTWs also felt that training' assistance related to federal regulations would be'
extremely useful. At the very least, EPA could provide continuously-updated regulations on the
Internet for local program managers to reference. Changes could be highlighted so that managers
could easily identify how changes were likely to affect their workload and responsibilities.
The larger POTWs had formalized training programs. One such facility has developed an
internal training manual that all new inspectors learn during their first two years on the job.. Another
program has developed formal skill categories for employees and runs internal training sessions on
various topics throughout the year. Partnering on inspections is another approach often used in the
larger districts to train employees in new areas.
Some anecdotal information on favored approaches follows:
* One POTW mentioned Kenneth Kern's series of guidance manuals (put out
• by California State University, Sacramento) as an industry standard.
• Some POTWs felt that videos would be more helpful than written materials
for a number of reasons:
- — They could be lent to Ills as well as used by inspectors. .
-- They are useful to both visual and aural learners.
They can contain many subtleties of a site visit, such as how to
introduce yourself. '
They provide an important resource to small programs where there is
a limited diversity of IU industries.
',' " .'••••' ','',!,„,, • »
• Written materials remain important as reference tools, however.
• One POTW felt that inspector certification would be useful as well. While
already required.in California, broader application of minimal standards
might help to bolster the professionalism of the business.
• industry conferences offer a good opportunity for continued learning. One
POTW wanted EPA support for the Association of Metropolitan Sewerage
: Agencies (AMSA) pretreatment conference to continue.
• One POTW has developed its own training manual for inspectors that
inspectorslearn overtheir first couple of years on the job. EPA development
documents were helpful hi developing this manual.
• i - , ' •) .: : ' -':, • ' ' :• " ' •• .•'.••: , ••' i , • >:i • • -' . "• '•,. . . -' •• • :•• ',.• : •.. .",•< ; •
4-14
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Smaller POTWs faced unique training challenges because they did not have the internal
resources to cross-train through rotation. Certain industries or issues simply do not exist within their
districts. For these POTWs, developing networks with the surrounding POTWs was deemed one
solution, Inspectors could travel to attend training sessions or inspections; at the very least, they .
could have a telephone network with other inspectors to help them address new challenges. Use of
EPA's PIPES bulletin board could also serve as a networking device for pretreatment coordinators.
OUTREACH
Outreach generally focused on industrial users both large and small. Where classes of users
needed to be educated regarding new requirements or best management practices, the larger POTWs
would work through trade associations and community groups, as well as through local newspapers.
Two of the programs had initiatives targeting immigrant subgroups, and produced materials in
Korean and Spanish to reach them. -One of these sponsored workshops for the Korean Drycleaners
Association as another way to'educate small lUs.
The industrial advisory council approach was also used by at least three of the POTWs we
visited. The Councils provided pretreatment program managers with sounding boards regarding rate
structure, outreach, and new regulations. Working through the Councils, program coordinators were
able to disseminate information and reduce fears in the IU community. For POTWs that historically
had strained'relationships with their Ills, the Councils provided a forum for rebuilding trust and
cooperation between industry and the POTW. ,
^ ^The Cpuncils, by design, have tended not to include environmental groups. This decision
is based on their purpose of informing the industrial community about compliance issues rather than
serving as a forum for policy discussion. Some program managers thought that including non-
governmental organizations (e.g., environmental groups) on these councils would be divisive and
prevent industry from stating its concerns.
PRETREATMENT RESOURCES AND COST ACCOUNTING
Even the best performing POTWs had limited information on their cost of providing services
to specific classes of customer or managing certain types of constituents. In addition, budgets
appeared to be developed on a cash-flow basis, with little or no use of multi-year capital accounting.
As a result," there are multiple levels of cross-subsidization within the pretreatment program, and
between pretreatment and other municipal activities. These cross-subsidies make it difficult to
prioritize areas in which to focus pretreatment activity, and can reduce the incentives of IUs to install
pretreatment equipment or minimize the use and discharge of constituents of,particular concern.
4-15:
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Budgeting
Budgeting issues centered on three main areas: use of capital budgeting; incentives for
improving program efficiency; and comparing program efficiency. -
• Capital budgeting. Capital budgeting is not always used; rather, the full
; costs are financed out of a single year's budget. For example, setting local
limits in one facility cost $200,000, nearly doubling the pretreatment
program's "normal" budget. However, the cost was not allocated over the -
number of years that the local limits would be in effect in. order to estimate
the cost of service.
„ « , ,„ - • „ ,: . , „ "\ , - • •••',' , ' • .- •• '.„,:''
As a result, budget demands can be volatile, and the POTW does not
'develop a normalized'estimate of their cost of providing service.
- . The POTW noted however, that it would be difficult to retain surplus
funds within the pretreatment program to finance a capital
investment, given the many other revenue needs within the
department and city. Therefore,:a debt approach would be needed
••' • • ' 0 .. • .', 'instead. ',.. . • '. ; \ . ,' '", ....... .^ .
• Incentives for jriiproving program efficiency. One of the programs is
allowed to retain surplus funds for use hi subsequent years. This has
provided them with an incentive to spend their budgeted funds more
,. efficiently (i.e., providing the same services for less money). The POTW
operates on a two-year budget cycle, and is allowed flexible line-item
budgeting so that spending can be shifted as needed to meet the critical
demands of the program. This differs from other programs, where fines and
penalties are returned to the general fund. The pretreatment budget in these
other programs, if not spent within a fiscal year, also reverts back to the
general fund.
'.• : ' '.-,! '"•, ', ;.••'.: \;,: - :;.' ;.;-: '" / ",''•.' ' ' ,•:••' "'^"':> '•';" '•••..'•..'; :('••"' V.: ••'''^''*'$:'i*
• Evaluating program efficiency. All of the programs have experienced
declining, budgets and, hi some cases, pressure to privatize all or a part of
their operations. One of the larger POTWs, hi grappling with these pressures,
was interested in what measures one might use to evaluate the efficiency of
a pretreatment program, ami to enable it to be compared to other programs
around the country. . ! '
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Cost Accounting
» I 'I' ' ! - ' '-
Accounting for the costs of providing wastewater treatment services is an important exercise.
for every POTW to undertake. Only when costs are allocated to particular classes of users or types
of dischargers can both the community and the industries make rational decisions regarding which
wastes to treat at the factory and which to treat at the POTW; how much water to-conserve; and
which constituents are most important to remove from the discharge.
The cost accounting and cost recovery programs varied widely among the POTWs visited.
Many POTWs did not know how much they spent to provide service to particular types of
dischargers, and did not know how much problem discharges such as metals or salt cost their
systems in higher maintenance, testing, or residual management expenses. Cross-subsidies between
water and sewer services and between different classes of dischargers were the norm rather than the
exception. This has generally resulted ,in underpricmg services to lUs and, therefore, an
underinvestment in source reduction-and pretreatment by these users.
Cross-Subsidies
Cross-subsidies refer to situations where the fees on particular types of dischargers are set
too low to recover the costs of the services provided to those dischargers. This shortfall is made up
through increased qharges on other users. A wide variety of cross-subsidies can exist within a
pretreatment program; each will cause different types of distortions. Examples of cross-subsidies
existing at the CA sites we visited are presented below; this is not intended to be a comprehensive
listing. .;.>-•
• Between Municipalities. One of the POTWs receives sewage from lUs
located hi an adjacent large city. While this city does pay a fee for sending
this sewage to the plant, it is likely that these charges do not reflect the
program's full costs of treating this discharge."
• Between the General Taxpayer and/or Water Consumer and the
Wastewater Treatment Program. A number of me communities we visited
have some fund transfers into the program from general tax revenues. The
size of these transfers varies by locality, m one POTW, for example, the
development of Local limits was entirely financed from outside the
wastewater treatment program. ,
12 For example, an SIU in this city is a major discharger of some of the constituents of concern
that prevent this POTWs from selling its treated effluent to the agricultural sector. This discharger
should bear a substantial portion of lost revenues to the POTW that result from this discharge.
4-17
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Between Industrial Dischargers. Most programs seemed' to undercharge
dischargers of constituents of concern,-such as metals or salt.
One of the POTWs wants to sell its treated effluent for agricultural
use, but can't due to salt content, primarily from water softening
operations (both industrial and residential). Currently, the plant can't
charge more for salt discharge, but wants to move in this direction -
including much higher charges on home water softeners. Longer
term, the plant hopes to divert brine wastes directly into the ocean,
thereby not contaminating its secondary effluent.
Between Industrial and Non-Industrial Dischargers. One of the POTWs
evaluated a cost recovery plan to charge customers based on their cost of
service in the pretreatment program.
The cost for RJs skyrocketed, to a level this facility thought might
lead, industries to relocate. Especially hard-hit were the small
categorical users, regulated based on statute even though their
discharges were quite small. Under the prospective system, their fees
would have gone from $100 per year to about $18,000.
In contrast, when these costs are allocated across all users, they were
Very low. As a result, they decided that the pretreatment program
benefitted all dischargers, and that fees should not be based on cost
of service.
Between Agricultural Consumption of Fresh Water and the Wastewater
Treatment Program. Heavily subsidized access to fresh water for
agriculture in California reduces the demand for treated effluent from
POTWs in the southern part of the state because the fresh water is too
inexpensive for farmers to seek out substitutes. Were POTW effluent able
to be sold for irrigation, the additional revenues would likely allow sewer
rates for all wastewater dischargers to decline.
Cost-Recovery for Pretreatment Program
One form of cross subsidy mentioned above involvedi transfers from water consumers or local;
taxpayers to wastewater dischargers - primarily industry. In fact, many pre-treatment programs are
paid for by general sewer or water users, rather than by the industries themselves. Where costs are
not recovered, industries may be benefitting from subsidized sewage treatment. Often, large
industries pay less, while residential or small commercial customers pay more. Aside from equity
4-18 '.
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concerns, such an arrangement may also reduce the incentive for industries to invest in pretreatment
equipment, there was a wide variation across the POTWs regarding the portion of pretreatrrient
costs paid for by industry and how these charges were structured.13 <
Interestingly, while a couple of people did mention that they were under pressure to keep
sewer fees low to retain industry, nobody felt that increasing discharge fees had been the primary
factor causing IUs to shut down. They did feel that rising fees encouraged the industries to minimize
discharges, however, through process changes or improved pretreatment. ,
' ' • - ' • ' . • • • ' r' , ,
• One facility does not charge its IUs a fee. In addition, laboratory costs
associated with particular IUs are absorbed by the city rather than charged to
the industry unless they are associated with ah enforcement action. In the
view of the POTW, ; .
',;.," " - " f ' '
The industries bring valuable jobs to the region.
The POTW does not want to penalize local business. Nearby
businesses, in a different governmental jurisdiction, discharge into the
plant but are not charged a permit fee. Therefore, the pretreatment
personnel did not wish to disadvantage their local industry..
• The service area for some of the POTWs continues to grow. Therefore, there ,
is. political pressure to keep sewer fees low in order to help attract new
industry.
• One program charges the same permit fees to all sized firms.
• AnotherPOTW originally recovered very little of its program costs fromIUs.
Is has begun to charge IUs for lab costs and sampling. Sewer fees make up
the rest of me annual budget. When the higher charges were explained to
industry, the firms did not threaten to leave; they actually felt that the charges
made sense.
— Commercial firms also pay for pretreatment because the city must
monitor discharge from this sector and! include it as part of their
headworks analysis. The charge is $2.25 per month.
13 Since commercial and residential users also contribute discharges that use of capacity for
particular constituents, these classes should also pay a portion of pretreatment costs. However, the
^current allocation of charges is often distbrtionary.
;. • .• . ' "4-19' -• • /. . •, •' ; ' '"..-.'. -;
-------
Innovative User Fees
Capacity Charges. Faced with the need to expand plant capacity but
Without the financial' means to do so, one of the POTWs financed new
construction by selling access to its system. Developers were not allowed to
begin their projects without purchasing access to the sewers in advance.
The system charged a fixed amount per EDU (equivalent discharge
: unit,- equal to approximately 250 gallons per day), the purchase of
one EDU gave a discharger the perpetual right to discharge that
amount per day, but these rights can not be bought and sold. Thus,
once purchased, capacity fees provide little incentive for source
reduction -- despite the fact that the market price for new discharge
pghts has risen steeply (to about $5,780 per EDU), thereby offering
existing industries large potential gains for reducing their demands on
the municipal system.14
Shadow-Pricing
i . ".i " ' ' ' i i ',' • ' ,i f " ' ' ' ' ' ' "'" '' t'' i ji 'i1'"' •'"' " i '•
In industrial processes, capacity constraints on a. single machine can limit production from
the rest of the plant. The machine in this example, known as. a "bottleneck," can greatly reduce plant
throughput, with important implications on factory profitability. Assigning costs to these
bottlenecks, equal to the value of foregone production, can help plant managers identify critical
changes needed in their plant in order to make it more efficient. ,-
:""' • ','' '.!)!•• ' : ': • T '''„•••' ••' :;'" •: ,;';:;:' :"'- .'' '•''(•''•)• ' •' *.:'.'•':. ! ': ^: •' ;''\VJ.:"'/" .' ..'-•V'^r^fLT'^.'':
- Waste water treatment is an industrial process, and can also be subject to bottlenecks. One
of the facilities provides an interesting example of how shadow pricing can help to improve plant
efficiency! The POTW has an average flow of about 15 mgd, and a capacity of 16 to 17.5 mgd.
While operating at close to capacity, there is between 1 and 3 mgd (between 7 and 20 percent of
current flow) remaining. However, because the plant shares an outfall with another treatment plant,
and this plant currently needs most of the outfall capacity, managers at the site do not think they will
be able to use the. foil capacity of their treatment plant. Thus, the outfall is a bottleneck.
: -Were the limited outfall capacity to carry a shadow price (where the plants would actually
pay a charge to use the outfall) reflecting the cost of being unable to use up to 20 percent, of the
plant's treatment capacity, managers in both plants would have a strong incentive to innovate. These
innovations could reduce the effluent discharged, or perhaps expand the capacity in the. outfall. In
either case, costs to the utility system and its customers would be minimized.
14 The lUs also pay a charge every month based on the gallons of water consumed, providing
some incentive to conserve water.
4-20
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Cost-Accounting and Beneficial Reuse of Effluent and Biosolids
The contamination of sludge and treated effluent with metals and salt can preclude its reuse
as soil,amendments and irrigation water. Proper cost accounting would help to solve this problem.
For example, a POTW that must landfill its sludge due to high levels of metals would charge all
metals dischargers the incremental cost of sludge disposal in a landfill versus disposal on a farm.'
The California sites actually visited all met land application standards for their sludge.15 As
a result, improper cost accounting does not appear to be affecting this aspect of operations. The
situation with secondary effluent varies. ManyfeeilJties'reuse- theirwastewaterforagricultural and
urban end uses. In other programs, very little of the treated water is being reused prior to discharge.
This appears partly to be due to contamination levels and partly due to the heavily subsidized
agricultural water available throughout southern California, eliminating much of the economic
incentive to use reclaimed water. In such cases, the lost revenues increase the costs of wastewater,
treatment to dischargers. .
» Constituents of Concern in Sludge. Primarily heavy metals.
• ' Constituents of Concern in Treated Effluent
Fluoride can precipitate out calcium. . '
Boron levels can hurt lemon trees.
— Salt levels harm many crops. Especially salt-sensitive crops, such as
avocado trees, can" be used to test the ability to use effluent in
agriculture. .
. Seleruum, molybdenum, and zinc are also constituents of concern in
**'-" effluent. . -
INFORMATION SYSTEMS
Improved Systems Would be Extremely Valuable
N; ' " . ' " ' * . .
The pretreatment staff universally felt that improved informatipn systems would benefit their
programs. The systems would allow them to provide their services more efficiently, as well as to
identify trends in discharges much more readily. Rapid access to basic data on lUs has proven to
be a powerful aid to enforcement. The systems have also reduced staffing needs. For example, a
15 Reuse of biosblids seems to have as much to do with shopping around for an interested farm
as with metals levels in the .sludge. For example, sludge was landfilled at one of the programs until
November 1995, when they identified somebody willing to take their sludge for land application.
The metals loadings had not changed. •.-..•'••
4-21
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combination of self-monitoring requirements and automation "allowed one of the POTWs visited to
reduce its inspection force by three positions. Staff are able to spend more time on evaluation and
inspection and less on administration.
While some of the larger facilities are investing heavily in information systems, there are
many opportunities for standardization, information sharing, and dissemination of successful systems
to the smaller POTWs. The benefits would be substantial. One pretreatment stafrperson (at a small
POTW) estimated that he spends about a half-day each time he gets lab results looking for data
trends. Formatting data for the various required reports and standardizing data forms would also be
helpful.
Information Systems Available to POTWs
Below is a compilation of information systems that were used by the sites we visited, or
mentioned by them. " •
. „ , * ' ,.'•*,, . . ' •',"•, ' , ! ,
• Oracle-Based systems. The larger POTWs tended to have a Laboratory
Information Management System (LIMs) to track laboratory samples. The
• LIMs would be linked to an Oracle-based database containing information on
permits, required sampling dates, etc. One information specialist thought that
a Paradox database could be used rather than Oracle to build such a system
. ,..." for a smaller POTW.
Many of the POTWs have spent tens of thousands of dollars
developing specialized programming to track trends, meet state and
local reporting requirements, and generate correspondence to lUs
-automatically. There exists tremendous opportunities for them to sell
these programs to other POTWs.
• Pretreatment Program Manager. An integrated, DOS-based, pretreatment
management program, this software was used regularly by one of the smaller
plants we visited, and had been analyzed by the other small plant. Staff felt
the software was useful, albeit somewhat rigid and difficult to work with.
The software retails for $4,500. It appears to be too limited for the larger
'. ' >:: POTWS. ;; ''_'." ";'""' ''' ' /' . ' ;; ., .; ' '. • '\ .!'..'.'*'!;. ,;"„:
- Contact: ARCCA Incorporated, 215/322-8396.
--- ARCCA wasivery interested in this CSI project and our findings. They are
' willing to work with EPA" to improve their program, and may be open to
, innovative ways of extending the use of the software among smaller POTWs.
4-22 •
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Prelim 4.O., This.program helps• pretreatment programs to set local limits.
The interview team did not get feedback from pretreatment staff on its
usefulness.
PCME. This software package, developed by EPA, was universally disliked
by every pretreatment staffperson we asked. The program was inflexible,
difficult to learn, and-not very powerful. Many had stories of frustration
related to their past attempts to use the software. :
' ' ' ' ' .•'-.•-.''' x •. • "• '
PIPES (Point Source Informatiow Provision an*ExcfeaageSyst€m)v This
is EPA's on-line bulletin board for many water-related areas, including
pretreatment: It was mentioned as a potentially valuable resource; however;.
many of the smaller programs did not currently have easy access,to the
Internet.
Use of Geographic Information Systems (CIS)
Most of the programs we visited have begun to develop GIS. The norm seems to have these
efforts start with the/treatment plant, to improve operations and maintenance of sewage treatment
capital and sewer networks. The links between treatment-driven GIS operations and the pretreatment
program is mostly hypothetical at this point, and there does not appear to be much input from the
pretreatment programs to help.shape GIS development. A number, of systems are linking into a
municipality-level GIS that includes basic data on industry such as location and business licenses.
Program staff did discuss numerous potential benefits of linking GIS to pretreatment:
.••"'. Linking business licenses to SIC data to help identify lUs and inform the
inspectors. . ,
• Locating lUs on the "sewer grid .and linking to sampling data to identify
contributions of particular pollutants to system trunk lines. For some
' , POTWs, this sampling data could be fed by automatic sensors located at
critical points along the grid.
• Integrating many water and sewer-related functions;suchas water networks, •
sewage treatment, pretreatment, stormwater.programs, brine lines, well fields,
, and even hazardous material response, with resultant improvements in ,r
accuracy and efficiency, •
• Informing the development of local limits. . >
4-23
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Challenges Facing Information System Expansion
.,-; ••• ., , .' : i •' ''.. .'•' '. - • . . i .'• •..• ', ; '.../,". .' .,'•,".•• •.. • . .;,l •
• Some POTWs have developed segregated databases to meet specialized uses.
While they acknowledge that an integrated system would be far more
powerful, the process of'integration can be a difficult task.
• Tailoring specialized analyses and reports can 'be time-consuming and
expensive for POTWs.
• Links between external labs and the POTW data systems are not very
advanced.
• Need systems that are user-friendly, and that the staff can modify.
OWNERSHIP PATTERNS
The POTWs we visited in CA had a wide range of ownership patterns regarding
infrastructure, management units, arid degree of outsourcing, .ma number of cases, fragmented
ownership of assets or overlapping jurisdictions created problems for efficient management and cost
.accounting. In other cases, pressure to improve efficiency had led to outsourcing of certain
functions, or developing additional capabilities in-house. The various patterns we encountered are
described below! It is too early in the POTW site visits to draw significant conclusions from the
patterns seen.
• ." One of the: facilities ownsme treatment system. However; the sewer systems
that feed the plant are owned and operated by the .local cities. Several
POTWs discharge to the East Bay Dischargers Authority, Coordinating
»among the many .different owners can be complicated.
» i"" , " , , • . _'.''l| . _' ' | ' '
.• One of the POTWs receives effluent from industries in a nearby large city.
Industrial users, frustrated at falling into two management jurisdictions,
petitioned to be shifted into the city district. The city now runs the
pretreamierit program; however, since the effluent from this area still flows
: into the POTW in another community, the city inspectors do not have a good
understanding of issues confronting the plant. To address this issue,
' inspectors from the POTW will often conduct joint inspections with the city.
: m addition, they do have some input into me discharge permits that the city
; ' writes. , , , ..•...'• ,.
• One of the sanitation regions is divided into a number of districts. Each
district has a different sewerage surcharge, based roughly on the differing
costs of service. These have proven to be administratively complex, and may
1 ' ' , ' ' ' , "i ' • ' ' '"" " ' • ' , ' . ' ' , ' , ' " " ' ' ; ,''''
• . . .'': .' ''1; -" • '' "' '• . : • . '4-24 " " ' ''"' • ' . " "'• ''"" '
-------
be eliminated, the POTW has already outsourced a number of activities
• including biosolids hauling, design work, plant security, and legal counsel
(including enforcement).16 ' _ ' .
Laboratory Operations
Sampling and analysis of samples provide a core component of the pretreatment program.
Whether laboratory operations are run in-house or outsourced; the pretreatment program must
coordinate closely with lab personnel. The degree to which lab operations; are outsourced represents
a trade-off between economics and convenience: .
• Enforcement cases require a great deal of staff time. One of the PQTWs
contracts for most of their lab work even though they are certified to do it in-
hpus'e. The pretreatment manager prefers hot to have his staff tied up with
QA/QC issues related to.pendmg enforcement actions.
• •".'. Specialized analyses are generally outsourced. Where the needs for a
'-.'•.'• particular analysis are infrequent, even POTWs with extensive internal labs
-tend to rely more heavily on external laboratories.
• Internal analyses may be faster. Quick turnaround, greater control over
testing conditions, and the ability to link results easily into POTW data
• systems all favor internal testing.
Comparing the economics of infernal versus .external testing is not straightforward. For
'' example, because Ills must do self-monitoring and send the samples to contract laboratories for
analysis, they can easily compare charges to fees for POTW in-house sampling. This keeps pressure
on the POTW Wbs to be cost-competitive. In fact, one facility says their lab costs are so low that the
private sector has asked them to run their samples. However,-meeting external lab prices does not
necessarily mean the internal lab is as efficient. The internal lab does not earn a profit (allowing it
to underprice private labs, all else being equal), and may be subsidized by other aspects of the
POTW operations. » _
16 The enforcement portion of this function may soon be brought back in-house.
.".''''''.• • • • ' . . • - •'• " .'•'.-- * • . - • .
. . - . ' ' • 4-25 • '•
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"tn-Sourcing"
' Outsourcing refers to shifting a function previously performed by internal staff to an outside
firm. "Inrsourcing" refers to the opposite: internal staff taking on a responsibility previously -
performed by an outside entity. Both forces are occurring simultaneously within the POTW arena,
though in different areas. One POTW we visited was especially interested in expanding its
experience with site inspections and waste water treatment systems into the stormwater program,
previously run locally. "In-sourcing" can offer important benefits to the POTW:
• ' Skills of its inspectors can be utilized, rather, than having to train an
additional set of inspectors for a much narrower job. .
• Inspection efficiency can be enhanced.
• The skills of pretreatment inspectors, in conjunction with their presence in
the field already, can provide significant cost savings to the taxpayer over the
current dual-inspector system.
' • The additional responsibility can bring in additional revenues to the POTW,
as well as expose the inspectors to new potential dischargers.
•i' ,,p ", , . ' i , . ' ,',_' ,''',' M|ii , , ,
Another of the programs has brought equipment repair in-house in order to save money.
Previously, equipment had to be shipped to the manufacturer in another state, at great expense both
in terms of cost and time out of service. POTW staff have recently been trained by the manufacturer
to do the repairs themselves, with substantial benefits to the POTW.
„ .,,MI,,, ,, , • , "• '.,,,' ', , , . • - .
KEY FACTORS IN IMPROVING PERFORMANCE AT UNDERPERFORMING POTWS
Operations of Treatment Process a Larger Factor than Pretreatment
Two of the PQTWsin California had faced compliance actions in.the past five years. Both
felt that their programs were now in control, a conclusion that regulatory officials seemed to concur
with. Interestingly, in both cases, pretreatment program managers felt that improvements in plant
operations rather than the pretreatment program were the largest factors in bringing the programs
back into compliance. In both cases, as well, the enforcement actions had created an atmosphere in
which new managers were able to take over the program in a turnaround-type situation. Funds were
made available to improve the treatment program, and the past failures made staff changes and new
operating procedures possible to implement. New staff and resources were brought in, and, in some
situations, old staff were forced to meet employment expectations that they had not previously been
meeting. , ' .
4-26
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One of the .sites visited felt that although, the lUs had often been blamed for
plant failures, the operations of the sewage treatment plant itself was more to
blame for plant upsets. In addition, new local limits that scaled from lUs to
the entire user base to incorporate the dilution from the other sources (and
were therefore easier to meet) brought the POTW out of technical violation.
- Within the 'pretreatment program, two changes were implemented to
improve plant operations. First, major industries were targeted for
additional scrutiny. Second,' nT'perfbrmanee was tracked' more
carefully. . ,
— The action also gave them the power to enforce fines that it had
previously lacked due to jurisdictional issues. •/...
In one case, the program manager felt that local limits were very important
in helping him set priorities.17 Their major technical problems, however,
were associated with poor process controls in the sewage treatment process,
rather than with industrial discharges. In their estimation, 95 percent of the
improvement in their program was due to operational controls, only 5 percent
was due to pretreatment. , . .
Challenges for Smaller PQTWs
Expertise. Training and retaining inspectors and engineers capable of
reviewing permits and providing useful feedback to lUs. .
Classifying Ills. The federal regulations can be difficult to understand and
continually change. Proficiency in the regulations is a substantial task, and
poses a large fixed cost for smaller programs. One.small POTW had
misclassified some lUs, an oversight the EPA's regional inspector brought to
their attention. As a result, some Ills made investments to comply with
particular standards and later had to reinvest in new equipment once the
misclassification came to light. •
17 However, they were forced to set local limits for over 70 pollutants. Most other POTWs had
limits for only 15. The large number has imposed a burden on them for monitoring and testing, and
the pretreatment program manager feels thatmany of the limits are unnecessary.
4-27
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SUMMARY OF SUGGESTIONS TO EPA
• Put guidance manuals on the Internet. Older documents aire hard to find
onde they are out of print; having them on-line would solve this problem. ^
(EP A's PIPES bulletin board does have a number of guidance manuals on-
line. These appear to be text files, suggesting that useful graphics are not
included. Expanding the menu to include all of the'documents pretreatment
staff find useful' as well as putting them in PDF rather than TXT formats,
would add value to the existing offerings.)
• Provide updated regulations of relevant to pretreatment on the Internet
Any layman's guide to these regulations would also be useful to a number of
the program staff with whom we spoke.
• Higher Presence of EPA Regional Inspectors. Pretreatment program staff
had mixed'reviews of state regulators. However, they all felt that they had
benefitted tremendously from the knowledge and suggestions of Region 9
"inspectors .Those facilities farther away from San Francisco wanted a much
stronger presence of the inspectors than was currently occurring. For
example, some of the smaller programs said they could go years in between
inspector visits. . .
• Mention the Positive In Audit Reports. Where programs have improved,
pretreatment managers wanted EPA audit reports to acknowledge these
improvements in the audit report, rather than only listing the program
shortcomings. Pretreatment managers must compete for .attention and
resources with many other municipal needs, and positive feedback is a
powerful motivator for their staff and for their superiors.
• More EPA Interaction with Utility and Public Works Managers. EPA
-contact with utility and public works managers could help boost the status of
the pretreatment program in the eyes of these managers. . .
« Encourage Use of Mass-Based Limits. According to one of the POTWs
: visited, EPA has backed away from mass-based limits in recent years. This
has led some lUs in the service area to increase water use in order to meet
concentration based limits.18
;,=;!],
i!
••'l!
18 In some cases, high concentrations of toxins could cause plant upsets, arguing for a balance
between mass-based and concentration-based limits. Staff say this is not a problem in large plants
because slugs pose very little risk of causing an upset.
' "•'*• : " •'• ' ' .• ; •' ;- ' "••'• " '4-28 '
i':;; !! • Mi;
-------
Set De Minimis Limits for Categorical Users. Small categorical users
often discharge such low levels of regulated constituents that they have no
effect on the*POTW meeting local limits. Eliminating these users from
regulation could result in substantial cost savings with no discernible
environmental impact.. An alternative to a de minimis exemption would be
to allow the POTW to exempt small dischargers if they were not affecting
compliance with the NPDES permit.
Relaxed Restrictions-en the Use of Reclaimed Water. Mostly a state issue.
; * ' - *~ -. s 'f " '
Greater State or Federal Involvement in Setting Local Limits or Writing
Permits. According the one of EPA's regional inspectors, local limits and.
permit writing can be extremely difficult for the smaller POTWs to do well.
Greater involvement at'the state or federal level might improve the results jin
these areas.1?
Re-examine the Concept of Significant Non-Compliance (SNC). One
POTW felt that the current definition of SNC did not target the facilities that
had the biggest problems. This conclusion is based on two factors:
- As non-compliance levels rise, the frequency of testing required rises
as well, allowing extremely poor test results tp be averaged across a
much larger sample of readings, m contrast, a plant with no history
of violations that has one test come back out of compliance will have
a small number of tests over which to average the poor result.
— - A 20 percent variation between the standard and the test result can,
for certain tests, be statistically-insignificant.
Increased Attention to Bioaugmentation. One POTW felt that many,
1 bioaugmentation options were underutilized because many plant operators
did not know about them. Existing products could provide odor control,
corrosion control, and achieve rapid drops in required BOD. They can also
help a plant to recover more quickly from an upset.
19 The larger POTWs have-'established fairly automated permit-writing using boilerplate text.
Some of these approaches may be transferable as well.
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SUGGESTIONS FOR THE CSI PROJECT
• Evaluating Impact of Privatization. How do POTWs compare to privately-
owned plants in terms of their structure and their efficiency? How might
privatization affect,pretreatment and environmental performance?
• Benchmarking. How do you compare across POTWs to evaluate program
efficiency? How does one document productivity: focusing on results rather
" than on actions? ..... ;
Barriers to Energy Recovery with No Environmental Benefits. One of
the plants generates methane from its sludge digester that it wanted to use to
fuel plant operations, the city requires such energy recovery operations to
be permitted, but the POTWs methane contained, too much NOx to be
permittabie. As a result, the methane is flared off (the city has no regulations
on flaring), and the exact same NOx is released to the atmosphere without
energy recovery.
"' ', . ' ' , ' „'.''', "'.. ' ' • ' !' " . ' '' •',,,-
Reducing the Burden of Inspections on Ills. EPA and pretreatment
inspectors bom mentioned that they are often met with resistance by the IDs.
Much of mis, they believe, has to do with the large number of government
Officials these industries must deal with. According to an EPA regional
inspector, there are 26 agencies that do environmental oversight in California,
creating a burden especially for.small businesses. Multiple inspectors (local,
state, and federal) for the same media are especially duplicative. .
-L There has been some talk of a "super-inspector" that would visit a site
and inspect for all programs at once.
The general feeling was that such an inspector would not have the
Specialized knowledge to do a good job in any of the media areas, and
would not be viewed as an informational resource by the industry.
However, people 'did feel that a single inspector for each' media,
covering all levels of government, might be possible.
A number of the pretreatment staff felt that greater coordination
between inspectors on when they visit a site might be possible.
-- Another possible solution is "equivalency" for permits and reporting.
This would reduce the number of modified documents that a firm
would need to generate for the various regulatory authorities.
4-30
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Attachments:
SUMMARY OF INDIANA POTW SITE VISITS, MARCH 25 '- 29,1996
SITES VISITED
The Gity of Elkhart Wastewater Treatment Utility
The City of Fort Wayne Wastewater Treatment Plant, •
Richmond Sanitary District _ ;
Connersville Utilities , , -
The Bureau of Water Quality, Muncie Sanitary District
Interview Team: Jim Casey, OPPE; Greg Waldrip, OECA; Patrick Bradley, OW (for Richmond,
Cbnnersville, and Muncie); Matt Gluckman, EPA Region 5 (for Elkhart and Fort Wayne); Doug
Koplow, EEc. , • : :
NEW INSIGHTS FROM THE INDIANA VISITS
* Political support for pretreatment is important. Requiring industries to
invest in pretreatment equipment can be expensive. In a number of the cities
we visited in Indiana, high unemployment made the city councils and utility
boards reluctant to require anything of industry that might induce them to
leave: This historic lack of support for pretreatment made it difficult for
program staff to pursue even cooperative solutions, hi some cases, the lack
of pretreatment led to problems at me POTW and reduced sludge quality--
forcing the city to incur substantial financial costs.
• internal "PR" is as important as external PR. Small pretreatment staff
within a much larger utility were sometimes lost. They did not get
information from other parts of the organization quickly (such as unreported
discharges), and the other parts did not understand how pretreatment could
help them protect their sewer infrastructure. Staffing resources were
SometmiesdisproportionaltotherequkementsofthePQTW,andwerenot
always utilized across departments when things were slow in one area.
, , . , • "* , ' ' . . - " ' • . . ' t . / . - .
• Programs operating under expired NPDES permits not always aware of
the large changes they will face as permits are renewed. Although in
compliance with their old permit, a number of programs will face substantial
challenges as they must meet newer discharge limits, install dechlorination,
and incorporate whole effluent toxicity testing. Many of these programs have
not adequately begun planning ,for this transition.
,'•'''? ... .' " ' .. ' 5-1 ' '. ' . . " .'•-,-
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Focusing on a river or watershed, rather than a discharge point, has
important benefits for environmental quality. NPDES permits focus on
allowable discharges to a receiving body rather than on the health of the
receiving body overall. Consideration of the mass loadings entering a
watershed and its effects must be better integrated. One POTW has adopted
this type of approach, giving a local regulatory agency control over both
indirect and direct dischargers to the local river. This has given them much
wider latitude to implement cost effective controls on all types of dischargers.
New staff in small programs need immediate guidance: Despite the
plethora of pretreatrnent guidance materials available, new program
coordinators need a "road map" of what running a pretreatrnent program
entails and how to use the existing literature effectively. They also require
some assistance determining the priorities of the program. This guidance
would help them "ramp up" quickly to being an effective manager even if (as
is often the case) there is no other staff on-site to train them.
Many POTWs and IUs do not know how to choose a good contract lab.
Despite the importance of accurate lab results, some Indiana staff were
concerned that both POTWs and IUs had trouble evaluating laboratory
options to be sure their samples were being accurately and promptly tested.
Small programs can leverage substantial nearby resources. Some
programs in Indiana have made effective use of nearby, universities and
' prerreatment programs as resources to help them do their job better. They
have also linked with wastewater and water personnel to improve sampling
coverage and coordinate joint problem solving. Though not always easy,
these approaches have made small pretreatrnent programs much more
effective. „ ' , • r . '
Age of pretreatment program affects resource requirements. Older,
established programs are operating in "steady-state." IUs are under control,
systems have been established and refined, and working relationships have
been established to deal with problems that do arise. Newer programs (or
' programs under administrative orders) face large tasks in all these areas, as
well as in learning all aspects of the program.1 As a result, they will often
require more resources for a given size program.
1A well-established pretreatment coordinator pointed out that material he's learned over 25 years
is now required of new pretreatment coordinators hi 3 or 4 months.
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.Smaller programs have less resources to promote pollution prevention.
"We'd like' to do more," or "It's one of our goals over the next couple of
years," are common statements at the smaller, programs. With very little staff
and often large programmatic challenges, these programs simply do not have
the information or me time to conduct P2 outreach and education. Ways to
reduce the difficulty of providing P2 information to lUs would be helpful
Geographic Information Systems (GIS) are being implemented nearly
everywhere, but benefits to.pretreatment are still a few years off. GIS,
which computerizes core geographic data (such as sewer infrastructure, roads,
buildings) and allows rapid access for updating or analyzing, is being
developed in nearly every city we visited. However, the effort is in its early
phases, and focuses on sewer infrastructure. Parameters of concern for
pretreatment will be added, but not for a few more years. EPA could help
shape this implementation by illustrating the value of GIS to pretreatment.
MOST CRITICAL FACTORS IN RUNNING A SUCCESSFUL PROGRAM
There were many similarities between California and Indiana in terms of critical factors in
'running a successful pretreatment program^ The Indiana perspective is summarized below. .
Staff Expertise
Coordinators in small programs mentioned how important it was for them to understand their
responsibilities and the various approaches at their disposal for enforcing the law. There was less
discussion about understanding the industrial process at lUs in Indiana than in California. The focus
here was more on expertise on the requirements of a pretreatment program and innovative ways to
meet them.
Balancing enforcement and education during inspections
• ' '' - '• •'••'' . • - '< ' :
, This issue came out In most of the site, visits.
• POTW A found that it was very important to explain why certain things were
being required of IUs.. Once firms understand why something is needed:they
will generally do it.
"•'•-- More than 50% of jobs in conimunity are in manufacturing.
Therefore, the pretreatment program has always emphasized
establishing a working relationship with industry.
•••'.'••••" ,.' '.-•.:" ' •• •:'•*..5-3 • -" '
-------
As soon as there's a problem, legal staff: take over from pretreatment
staff, so as not to contaminate the relationship between IUs and
pretreatnient personnel.
POTW B found that once they moved from catching people to educating
them, DJ attitudes towards the POTW changed" and progress was more
• attainable. They are careful to provide general information on how to address
compliance issues rather than making specific recommendations that could
cause them problems later on if they didn't work. •
' ' ""',.! ' _ /
At POTW C the pretreatment coordinator will recommend consultants when
IUs have questions, but will not tell them what they need to do directly. The
coordinator will also help them if they are having trouble with their
paperwork.
* • • ' . '
At POTW D, the coordinator stressed the theme of working with industry on
joint solutions again and again. By assuming that industry wants to do the
right thing, and by helping them to find out what it is and implement the
solution, this program has made tremendous strides in improving water,
quality. Pretreatment staff are careful hot to make specific recommendations
to firms, though they will provide general guidance to small firms on how to
solve a particular problem.
This approach has had equally positive results with both small local
companies and with large firms headquartered in the city.
Where, there are violations, POTW D generally negotiates a
compliance schedule with the industry. . This keeps Indiana
Department of Environmental Management (IDEM) and EPA out,
and protects the company from third-party lawsuits. In addition, it
formalizes a time line for new investment and reduced discharges of
concern.
.Their approach is not to fine IUs if there has been no environmental
damage, but to make them invest capital to correct the problem.
Political support is important
The Indiana site visits brought out the importance of the political environment in running a
good pretreatment program much more than was apparent during our California trip. A number of
the communities we visited in Indiana were small with few industries, and had only a handful of
large industries. Facing already high levels of unemployment, the pretreatment staff faced difficult
5-4
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challenges in protecting water quality. In other communities, staff noted that a stable, supportive
relationship with the political entity had made their jobs much easier, allowing-continued progress
over a period of many years. .-• .. -
• Supportive relationships help ensure continued progress. One particular
POTW has had the same, environmentally-supportive, mayor for twelve
years. This consistency has allowed the pretreatment program to continue to
progress: In contrast, a different Indiana facility for a long time had a mayor
who was also the head of a major IU that had* strongly .opposed EPA
regulation. Since this mayor was replaced, the pretreatment program'has had
a much more friendly environment in which to operate.
• Enforcement actions help overcome .local resistance. In a number of
programs, federal and slate progjram audits and,enforcement actions gave the
• pretreatment coordinator the power to make needed.changes in the program.
However, as in California, some of the Indiana programs complained that
state inspector were sometimes ill-informed and did a poor job.
• Politics within the utility also hampered progress. A couple of programs
we visited felt that there were problems with their reporting relationships. In
some cases, the POTW superintendents paid little attention to pretreatment
coordinators (short of plant upsets). La others, utility managers (overseeing
water, wastewater, solid waste, storm water, etc.), viewed pretreatment as an
afterthought . ,
— Poor relationships with utility managers can lead to under
staffing. Under staffing at some programs made inspections and
enforcement difficult to do. Most of the available staff time was
spent on administrative .tasks such as permits, and written
correspondence with industry. . ;
- Under staffing is not necessarily equal across all utility programs.
Within a utility district, there is sometimes surplus staff in one area
' (such as sewer maintenance) at thesame time there are staff shortages
in pretreatment. This-is especially true during the winter season
, where little sewer maintenance can be con4uqted. However, without
mtervention by the utility manager, these resources .are not more
' '.' evenly shared. In some of the districts we visited, utility managers .
felt that sewer staff were fully utilized; pretreatment staff (including
: -.''. ' , some who had worked with sewer crews) felt there was substantial
' slack labor.
5-5
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Close relationships between Ills and the utility board or city mayor
created problems. Other programs had difficulty enforcing against non-
coiripilers because the utility boards, overseeing their activities, were
comprised of many people from the regulated industries. For example, 4 of
the 7 members of a Utility Board in one of the cities visited were also
employees or owners of SIUs. This process undermines the pretreatment
staff because lUs will often complain about the "fairness" of inspections to
the board, with the expectation of undermining the inspector.2
Understanding of short- and long-term program requirements is critical
The NPDES, permits are generally the basis by which pretreatment staff evaluate the,
effectiveness of their program. At three sites visited in Indiana, however, NPDES permits had been
expired for close to five years.3 Thus, the parameters they contained were developed over ten years
ago, and are likely to change dramatically when the permit is renewed. While these programs are
generally in compliance with their existing permit, EPA staff felt :there would be serious
shortcomings were a "modem" NPDES permit used as a basis of comparison instead. Pretreatment
staff, as well as utility-level managers, did not have the information necessary to identify areas for
required improvement over the next five years. Some of the changes could require substantial new
capital investment.
Focus on Watershed rather than Discharge Point
Most pretreatment programs focus on meeting discharge requirements at the POTW outfall.
In contrast, one POTW is organized around a river. As a result, it regulates both direct and indirect
cfischargers, whereas most pretreatment programs regulates only indirect dischargers. Contrpl of the
direct dischargers has been critical in their success. In fact, the facility targeted the direct dischargers
first, and got them into pretreatment. , '
2 Even large, well known firms use this tactic. In one region, a large international firm (which has
won environmental awards, though not in water) rarely corrects deficiencies within the allotted 30
day period. This firm will also often write complaint letters" to the board. In this same POTW
region, a manufacturer of appliances, also a well-known brand name, dumped large .quantities of
nickel into the sewer, upsetting the treatment plant. .
3 According to personnel from one of these POTWs, the city's draft of the new permit has been
rejected because of a misunderstanding between the POTW and the Indiana Department of
Environmental Management (IDEM) over a combined sewer overflow (CSO) storage facility.
IDEM tijpught this facility was essentially a plant bypass rather than a storage unit.
. , ' '.' ;" .'. ..' ." .. '""'.'•; ' • '.' 5-6- " :' '"' ' '" : "
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IDENTIFYING INDUSTRIAL USERS j
/As with the California POTWs, most of the Indiana programs have developed effective ways
to identify new industrial users, in their communities, and generally think they have identified the
regulated universe.4 This includes reviewing yellow pages, obtaining information on construction
permits or applications for water or sewer hookups, changes in water consumption, and site visits.
One of the programs now requires a separate pipe for each tenant in a multi-tenant building. In the
past, they sometimes had trouble determining who was responsible for a particular violation.
The coverage varied somewhat across communities, as did the reasons that POTWs felt they
knew about-all of the industrial users:
• For verysmall towns, any new business means jobs and new jobs attract a lot
" of attention. In such cases, new Ills are quickly identified.
• One POTW plan doesn't think it's missing;any lUs because they have very
good baseline information and do mass balances for discharges.r New lUs are
identified from phone books,; direct contact with the local Chamber of
Commerce, and rrom calls from other lUs.
In contrast, another POTW expects it is still missing many Ills. The city has not conducted an IU
survey in six years. The last IU survey that was conducted got back many responses stating that the
pretreatment requirements didn't apply to particular firms; however, the POTW never followed up
on these to be sure. The pre,treatment coordinator would like to visit every one of these locations.
He believes that some lUs are permitted and shouldn't be, and that some aren't permitted and should
be. '•'-'.' ' . .- . . '•"'-.- •'.'.. : ;-.'
SAMPLING AND INSPECTION STRATEGY
Procedures for Inspections
Surprise inspections were an important component for all of the programs. In most cases,
inspectors were able to determine their own schedules for visiting sites, although they were required
to meet a minimum frequency of coverage. This frequency varied by community. One of the most
effective program's felt quite strongly that sampling frequently was a very important component of
.their program." Most communities rotated inspectors to balance their knowledge of a specific site
against a desire for them to become familiar with all the lUs.
4 One of the programs did think that it might be missing some auto repair shops.
'..'•'•'•' 5-7- " .-..'. - ' -.-
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POTW A gives only 10-15 minutes warning on its unscheduled inspections.
They, rotate industries among inspectors every year; fresh eyes sometimes
catch new things in the plant. The concept of rotating inspectors is also used
' by another facility. • .. • .
POTW B felt their current sampling frequency was adequate or could be
reduced; there was not a need to "hammer" local industry if the POTW is
meeting their limits. Current sampling is 4 times per year; self monitoring
is required at least once every two weeks for any IU with compliance
problems.
The POTW does'not compare sample results from IU self-monitoring
with POTW testing to identify potential problems.
This treatment facility has had to develop very specific procedures for
dealing with split samples;as a result of data quality challenges from
, local industry.
POTW C uses maintenance workers to do IU sampling. The pretreatment
.' coordinator is afraid that the current sampling program doesn't work because
IUs manipulate flows. Since this region has a small number of IUs, the
program coordinator would like to have dedicated samplers to overcome this
problem. .
^ • Another establishment has 10 dedicated samplers. This is easier for
staff collecting samples and less disruptive for IUs.
POTW D is a "maintenance" program, where nearly all IUs have processes
in control and are in compliance. However, the pretreatment program still
chooses to visit each facility at least four times per year. This higher
frequency keeps the relationship "fresh"andthe inspector and plant operators
on a first-name basis. , .
t POTW E thought that better coordination between the inspector and the
sampler would improve the efficiency of their program.
Slug Protection and IU Process Controls
/ ' ' . " ' ' "', ,' ' * ' , ' , "
Advance Detection of Incoming Chemicals and Tracing Discharges Back to their Source
• Trunkline Sampling. A number-ofthe plants visited conduct trunkline
sampling. In some cases, data are collected regularly and provide a baseline
for any slugs. Most of the facilities, however, sampled trunklines and lift
• ' • • • ••• '• .- • 5-8 ' '• ' " ' '
-------
stations only when a slug or strange discharge was detected in the system.
Investigative testing was then conducted to work back from the main lines
•and identify the source of the non-permitted discharge.
— One facility conducts daily testing at a series of upstream lift stations.
'""'''• This data helps the POTW detect changes in the influent and catch
illegal dischargers. Data are put into a database and evaluated for any
spiking.
— Another of the POTWs"feas«fiv©iintefce^ors^and»tests:allof them
whenever a slug is detected. This approach gives them a reasonably
good chance of finding the discharger. The interceptors are not tested
on a regular basis. .
A third POTW does some trunkline sampling, but it's not necessary
to do very often since the pretreatment program has discharges in
control. They have done dye testing from each industry so they know
the time of travel from each IU. This makes it easier to backtrack an
illegal discharge.
Enlist Other Departments to do Testing. An inexpensive sampling kit for
each public works and utility vehicle has been developed by one of the
POTWs,. This kit, which their maintenance staff was able to assemble, allows
them to collect a usable sample if they detect discoloration or a strange smell
in the sewage. Prior to the kits, personnel would call the pretreatment staff,
but the strange discharge that had prompted the initial call was usually gone
by the time pretreatment staff arrived, •
Unannounced Sampling. As in California, unannounced sampling is used
by the POTWs as an additional way to detect illegal discharges. The use of
dedicated samplers (noted above), in addition to making sampling easier to
do, also reduces the ability of the IU to alter production parameters to affect
the sampling result. , .
Communication of Problems
Rapid communication of potential problems is very important in identifying
illegal discharges. One pretreatment program often does not hear about
problems until it is too late even to take samples. This makes identifying the
discharger virtually impossible.
5-9
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Oversized Plants Less Susceptible to Slugs
• One o f the POTWs felt that slugs were unlikely to lead to plant upsets
because there was so much spare capacity at the plant. [It is likely that this
protection is provided by a small industrial flow relative to total flow (about
15%) more than by the excess capacity in the plant].
Ensuring a Process is "Tn Control"
A common theme in the California site visits was the importance of ensuring that an lU's
process wls' "in control:" Such a process was less likely to be out of compliance, and, if out of
compliance, the operators would know how to get it back into compliance quickly. One of the
• Indiana programs also stressed the importance of this approach. However, some of the other
programs did not discuss this point. It is our observation that programs with little political power
to take actions against lUs were less likely to be able to ensure IU processes were -in control.
On a somewhat related topic, a nearby university, is helping one plant by conducting research
into "helping to make POTW digesters more resilient against upsets by varying certain parameters
of treatment such as residence tune.
ENFORCEMENT STRATEGY
Enforcement Action Sometimes Difficult to Take
•."."• ''.'." ' • , . ., :, •.,.'.• '' ' ' • •• •. ' i111. .>'
As mentioned above, a couple of the POTWs visited have a working relationship with their'
lUs For these facilities, they are notified early when there is a problem, and work together to
quickly correct it Others face a difficult task in trying to enforce due to political pressures.
* Notice of Violations (NOVs) Not Escalated. One of the treatment facilities
visited traditionally enforced against lUs up to the legal requirements,
treading carefully to avoid any action that might threaten the industry: NOVs
were not escalated, even if the.IU didn't comply. The first fines were not
levied until this year; in prior years the city had generally been unwilling to
fine industries.5 Fines that are levied now are refundable if the IU meets
certain deadlines in the appointed'time frame. The city attorney is now
helping me program to address non-compliant industries.
1 ,!«
5 The recent change was due to a new mayor, a new city attorney, and a new member of the 3-
member utility board.
5-10
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Warning Letters Instead of NOVs Make it Easier for Pretreatment
Operators to Regain Compliance. Political pressures in one of the cities
make jt very difficult for the POTW to fine violators. This area has one of
the highest 'unemployment rates in Indiana, so the city is wary of anything
that might cause industry to leave. IUs have recently begun to respond to
POTW .concerns. The pretreatment coordinator thinks this is because the
pretreatment program shifted to a lessrthreatening letter that still meets the
requirements of the law:
Reports self-monitoring-test results- and- BQT-W test results,, along
with a paragraph explaining their violations. <
Top management is not required to sign these letters, so the
pretreatment plant operator doesn't have go to the manager — they just
have to correct the problem. If the problem is not corrected, a formal
NOVissent. -
Another POTW also felt that such letters were often quite valuable because
they gave the plant wastewater treatment operator the clout to make changes.
Sharing Information With IUs Makes Enforcement Response Less of a Surprise
Programs try. to -share information with the regulated community to make their enforcement
response less of a surprise.
• Regular Reporting of Test Results. One POTW sends test results to the
IUs even if they are in compliance.
• Share Enforcement Response Plan (ERP) with Ills. An enforcement
. response plan gives IUs a much better understanding of what happens if they
don't comply. .One of the facilities plans to send every IU a copy, of their
ERP once it has been completed.
" - - • '* i - " - ' - (
— Many of the plans in Indiana are modeled after the ERP developed by
Muhcie.
Structure of Fines Can Help Support Program Goals
i • • .'••.,. . . . "• . • • • •'•-.••
Fines are also structured to,improve the likelihood of firms implementing the desired
behavior. ;
5-11
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High Fines for Grease and Oil Violations. One POTW mentioned that it
levies steep fines on companies that block the sewer lines with grease,
forcing the POTW to clean them out. The purpose of this charge is as a
deterrent, so that the restaurant owners see it in their economic self-interest
tq conduct proper maintenance of grease traps.
' Conditional Penalties. Two POTWs mentioned that they have been
successful levying penalties that would kick in if stipulated changes weren't
made by a certain date. . - w-
1 >! i ii . «, " • , •• • j
_ ', '' '. i " " ' i '•!' ,' I- :J ' | • • .. .-•'.. i •.. V1 ", ,j • '• ' .,•:' IM . •' ''. •'• :'_;. ... ' •.'•''•''.. l' "''i'',
No Fines for Rapid Correction of Problems and Which Caused No
" EnvironmeiitaiHarm. One facility allows 30 days for an IU to come back
into compliance after a violation has been detected. They will resample in 30
days, and, if the violation has been corrected, they will not require an increase
in sampling frequency, unless the IU has a history of violations.
Publication of Significant Noncompliapge (SNO 6ften Not Noticed
0 Publication of SNC. SNC notices are often buried in the legal section, to
meet the requirements of the law at a minimum cost. This reduces the
deterrent effect of adverse publicity. Providing greater visibility in local
newspapers of SNC violators cited for direct environmental harm might make
the SNC publicity more effective a deterrent. Similarly, one POTW thought
that if EPA consolidated the SNC reports and published a complete list, it
would be a more effective incentive to^ comply because patterns in corporate
behavior across regions would be visible.
' POLLUTION PREVENTION (P2) ' ' " '; '.';''.'
Pollution prevention was.not somethingthat^waswell established in the programs we visited.
In addition, a number of interviewees felt that the economic benefits of installing P2 equipment and
processes were bften not favorable, or, if favorable, not very significant in terms of the overall cost
structure of a firm. More focus was placed on program maintenance and fulfilling the requirements
of the NPDES permit in place.
5-12
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Other Program Priorities Have Taken Precedence .
. '• One pretreatment program said it has not been able to accomplish as much
. in the P2 area ;as it had hoped. With access to detailed information, their
inspectors'could help ILJs reduce pollution, which would be of great interest
„ to both the POTW and to their lUs. ^ •
-- This program is working with Purdue and Notre Dame to develop a
strategy for introducing P2 into local industries. They are pursuing
an economic approach, by trying to quantify the payback associated
with specific P2 investments. • •
-- The Notre/Dame researcher; thinks^
lead to more viable opportunities forimplementation being identified.
Providing the inspectors with 1-2 page summaries of P2 options
would also help.
-'• He thinks an expert system approach might be useful, but he didn't
have the expertise to judge its merits as compared to other approaches
of providing information on pollution prevention alternatives.
• Purdue University is initiating a pollution prevention site on the World Wide
Web. It will initially be geared to wood finishing, and will expand later to
metal finishing. The site will list P2 options available to particular industries.
• Two of the other programs visited saw little interest from industry about P2
opportunities. They tended to receive many more requests for information
on disposal options than.on P2.
• A fourth program noted that while it does encourage P2, water conservation
measures by large users could have a noticeable and detrimental impact on
' plant revenues.. "
Benefits from P2 Investments Mav Not Be That Large
" • An electronics manufacturer in orte POTW district discussed economic
: incentives for upgrading pretreatment equipment. All environmental
compliance costs were less than one percent of his cost of goods sold
(COGs),6 implying that large changes in compliance costs will have little
impact on environmental investment decisions. Wastewater discharge fees
comprise an even smaller portion, less than 1/10 of one percent of COGs.
.6 COGs includes the direct materials and labor that go into making a product, but exclude general
administrative overhead. .
5-13
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--" ' Environmental improvements, in this case', are driven partly by
• regulations and more significantly, by corporate culture.
Acceptable paybacks on P2 is normally six months to a year; in some
cases, paybacks of up to 2 1/2 years may be allowed.
The fifth program visited felt as though P2 may be somewhat overrated. In
their particular system, nearly one-third of the permitted industries are closed
loop, a factor that may slow adoption of P2 by their industries.
- • Both pretreatmenf and process capital need WbW'rfear dbsolescence
at the same time in order for many retrofits to be economical.
- Industries in this system don't have all the information they need to
know their P2 options; the pretfeatnient coordinator thought that this
information would be valuable. . .
A key question for their lUs is whether the P2 or pollution control
equipment (PCE) will actually work as it is supposed to. This is very
. hard to tell ahead of time. •
.The impetus to invest in P2 varies widely by industry. - Three TUs
from here estimated that environmental costs, as a percent of their
cosVof goods sold, was 1.5 percent, 25 to 30 percent, and "the third
highest expense after labor and operating costs."
EMPLOYEE ISSUES \ '. _ ' ' '_ ^ : ' . • '
Keeping the job interesting remained a key employee-related issue in Indiana as it had been
in California. Some of the same solutions have been implemented, such as developing teams that
cut across traditional organizational barriers.
• Coordination Across Functions. One POTW has developed multi-
functipnai teams, combining personnel from sewer maintenance, laboratory,
engineering, plant maintenance, and information systems. The teams meet
once per week to discuss problems and develop solutions.
The teams were created to reduce the overlap between personnel in
different departments and to encourage cooperative problem solving.
„ The utility manager consolidated water, wastewater, and the city's
' public works department for the same reasons. There are fewer
personnel, but they are better educated.
The multi-functional team approach has proven quite successful, with
staff quickly learning to work together.
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Expanding Jobs to Keep them Challenging. POTW. A feels that staff
retention depends more oh keeping the tasks interesting than on salary levels.
Their pretreatment program coordinator believes that they have many
opportunities for professional development within the.POTW for staff to-
grow into. ' ;
Retention. Staff retention at most of the programs has been fairly good.
POTW A retains staff for about four years. , Two, inspectors is the
norm, although at the time of our visit, they only had one.
POTW B has very low workforce turnover.
POTW C has extremely long staff tenure: Sixty percent of the
pretreatment staff has been there for more than 18 years. People who
"- leave generally stay for 4 or 5 years, then go to similar places and
become part of an informal network. Employees get high salaries and
good benefits. '
. c . ! i - •>-.'''. • • - ' * -'.•',
Some Staff Turnover is Useful. While long-term institutional knowledge
is important, the utility manager at one facility felt that some new employees
were a critical aspect in the health of the program because they brought fresh
ideas. - - ''. ' •',•-.-•'.,.; '-•-•."••.•.'.", "
EDUCATION/TRAINING ACTIVITIES AND INITIATIVES
Training was a big issue at the Indiana programs visited, including both pretreatment staff
and operators at the regulated industries. Perhaps the most unique training mechanism in Indiana
was the "Call John" approach (John Craddock of Muncie), utilized at least once by every program
we visited. State programs have relied on John for information on how to deal with political
interference, how to finance aspects of a program, how to prepare an enforcement response plan or
permit an industry, how to change a sewer ordinance, and how to conduct proper sampling. Many
programs, afraid to call state .or federal officials for help with a problem, have used John as a go-
between. ' ' . • • .
There were some common problems facing pretreatment coordinators^ especially in smaller
programs: •'•," l , •
• Time Constraints. Program staff don't have enough time to take advantage
of training opportunities. One program manager would like to train his staff
, more, especially at lower levels of me organization. They even have a budget ,
line item for training seminars, and think they would benefit from visiting
other POTWs. However, they do not feel they have enough time to take
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i
' away from their regular operations. The city is training upper managers on
managerial and leadership skills. Another program coordinator would like
to visit other POTWs, but can't afford time out of the district.
New Coordinators Don't Know "Where to Begin** in Running a
Pretreatment Program. A couple of the IN facilities we visited noted that
:. a "starter pack1" for a new pretreatment employee would be extremely useful.
This would provide some history on the pretreatment program, summarize
everything;one needs to do as a pretreatment coordinator,, including required
reports- and plans. It would also provide a logical roadmap for how to
sequence the many available materials into a strong training module.
discussed with John Craddock of Muncie how a small program in trouble might get back on
track. His recommendations:
• Get somebody from an established program to come to your plant and
conduct a mini-seminar. this seminar should provide: the staff with actual
examples, supplementing the: guidance manuals currently available so that the
staff can see what something (e.g., an enforcement response plan) should
actually look like.
- In 4 or 5 hours of discussion, he (or another individual) can give the
coordinator general direction and help him or her set priorities.
Shadowing another program is useful, and a number of people have
shadowed him.7 However, it is difficult for the "teacher" to complete his
normal workload. Shadowing also has some other hitches: Muncie's
insurance policy does not allow them to carry civilians in their field vehicles;
and some industries may not want to have outsiders in their plants.
Use state and federal water personnel as resources. They have a great
of knowledge, and appear; willing to help.
v
' One lacility's pretreatment coordinator came from the POTW lab, and had little training when
the former coordinator (who was supposed to train him) left. Learning what to do in the program
was extremely difficult. In retrospect, he thinks he would have been far more effective, if he had
spentthe first two months of his job shadowing another POTW program.
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Some of the other tactics used by smaller communities as training alternatives include:
• Links with surrounding universities. Our program has leveraged
pretreatment staff by forging working relationships with nearby Notre Dame
and Purdue. Students accompany staff on many IU inspections. The schools
are also used to help, fill openings within the POTW. .
• Links with surrounding POTWs» Program.stafilfiroin,one of the, BQTWs
participate in round table discussions with surrounding POTWs, orchestrated
by the^Indiana Water Environment Federation (IWEF). These round tables
have become a useful problem-solving resource for the staff.
The interviewees also shared their views on training tools that would make their jobs easier
or their programs more effective:
• Certification. In one case inspectors are certified operators, required to do
continuing education. Another POTW thinks it would be useful if lUs had
,-. to have licensed pretreatment officers. This would ensure that on-site
equipment was being operated properly. '"-.'.'.
• . Training Videos. Most of me POTWs we visited felt mat training videos
would be useful to help train the industrial users as well as pretreatment staff,
. as many of the industries do not understand the regulatory requirements:
— . Viewing inspector's notes from the audits on video would also be
..'••-' useful, to see what they are thinking as they go through a plant.
— One program manager thought the following videos would be useful:
sampling, conductinga show-cause hearing; computer systems; how
to perform an inspection; and how to determine an lUs industrial
category (i.e., SIU or CIU).
— One might also be able to videotape Water Environment Federation
(WEF) conferences. '.
• Regulatory Changes. Staying up-to-date ori regulatory changes is a
challenge. One site uses an intern to update the CFRs, though having this
electronically would be easier to use and take up less space. They also rely
on regulatory updates provided by the WEF and SNA. Another facility's Ills
felt that a non-legalistic interpretation of the regulations would be extremely
valuable in helping them to comply. '.<-..
.-' • Targeted Training Materials. One program mought mat more background
training on the new sludge regulations would be useful.
.' - . ' ' f "' ' . • ' " ,
i '"•/»• • = . • • • "
• . ; .' .. '.-' ..'".' . - 5-17-' .-' . - " ' ••;••. •"•• -, ';'-'.
-------
j'llli
1 . i . , i .1 ..: " • •.. . •„• ui, u .. IB i,,,
they are still overly general.
-- Topical seminars would be of more value.
The timing of courses is also important. Seminars at night are very
difficult for anybody with a family. .
The Rural Water Association (RWA) provides very useful training .
because they travel to plants. However, they don't currently provide
any pretreatment training.
OUTREACH ^ " '' ' [\ ' •' "';' ;' ;' '"./! . .' , . ". ". " . C"'..',,,....!'.
Programs had different views on the importance of outreach to industry. Many felt that
outreach was less important when there were not problems that needed working on.
1 , , i > • , • 1 i
Outreach less important as program matures. One program used to give
, talks to different industries about pretreatment options, and formed a
subcommittee at the local Chamber of Commerce to address water-related
' environmental issues. However, with their higher .workload (due to staff
vacancies and the need to train some new staff), they don't have enough tune
to do this anymore/ Since most lUs now understand the program,' this is less
important than it was in the past. (Note that the pretreatment qoordinator
stated that he did not think it would be necessary to fill the two vacancies
they currently had).
Some outreach is informal. Continual refinement of the sewer ordinance
has helped one program to put policies down on paper, making requirements
" clearer to Ills.
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Outreach does help build trust. One POTW formed a Clean Water Council
in the early years of its program to educate industry about the regulations.
This Council built trust with the IUs over the long-terrn;{ the pretreatment
coordinator is now always notified whenever an IU is having a problem with
discharges. - .
Outreach to the community is also extremely important. The
- pretreatment coordinator spends substantial time meeting with
neighborhood associations. As a result;,requests, for funding.become
less mysterious if the community understands the program's mission.
This POTW also runs an awards program to recognize successful IU
pretreatment efforts.
Internal publicity is also important. Some of the pretreatment programs
we visited are almost invisible to the rest of the utility. As a result, they do
not get the information they need from these other divisions, and potential
opportunities for cooperation are missed.
PRETREATMENT RESOURCES AND COST ACCOUNTING
As in California, the Indiana POTWs rely on a variety of budgeting and cost accounting
approaches. In the most extreme situations, pretreatment programs either did not have a budget, or
program managers did not know what that budget was. The degree of cost recovery for pretreatment
from industrial users also varied widely. , .
Budgeting
Capital budgeting different for different asset purchases. Capital
replacement, new capital, and sewer line extensions were sometimes financed
in different ways: .."-..
- One POTW has a replacement fund for capital equipment. This fund
accrues interest as it accumulates. The utility manager said these the
1 city sometimes targets these fund balances for "redeployment," but
are promptly "reeducated" about their original purpose.
New capital is not financed through these accruals in the POTW.
Sewer line extensions are paid for using economic development
grants, rather than through capacity charges on the beneficiary users.
Capacity charges are levied if the users are outside of the facility's
normal service area.
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One of the other programs has a reserve fund for capital purchases,
but the staff does not generally know how much is in the fund. Staff
thought that the new NPDES permit might trigger large capital
purchases that could not be financed in this way. ,
Lack of independent budget or budget information. At a cpuple of the
programs we visited, pretreatment staff had no budget and operated in the
dark about what resources they had at their disposal. Rather, they would
have to request permission to make most expenditures, and funds would be
allocated from a general utility or POTW account!
POTW A: The.POTW submits a proposed budget to the utility
general manager. This is taken to the utility board, and then to the
; city council. ' The city council must approve the budget, rate
increases, and sewer ordinance changes. Historically, obtaining this
approval hasn't been a problem. Staff believe this to be the case
• because the budgets have always been small. The staff don't know
what final budget gets approved, the wastewater treatment and
pretreatment prograhis simply make requests until they are denied by
the utility manager.
The pretreatment budget is part of the wastewater treatment budget.
The utility manager estimates that pretreatment receives $50,000 per
year out of a $1.6 million wastewater treatment budget (including
both debt service and O&M).
'. The city has spent a lot of money to build industrial parks with
complete sewer hookups. Some of these parks have never been filled.
The utility general manager also serves on the town's industrial
development board.
POTWB:95 percent of the pretreatment funding ispart of the lab
budget. Staff, including the lab director, are not given budget
information. Generally, it is not a problem to purchase consumables
or small equipment. Expanding employees is a problem. This
program has 1.5 full time equivalents (FTEs); they don't have a basis
, -, of comparison to see whether this is low or not given the size of their
community.
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Cost Accounting
Cross-Subsidies
It appears likely that a variety of cross-subsidies exist in the. present rate structure of the
Indiana POTWs. Many programs did not have detailed enough information on cost recovery for us,
to identify areas of cross subsidization. Common areas seem to be between industrial users and
.residential/commercial customers; between different industrial dischargers; and between the general
taxpayer and the industrial discharger. The cost recovery approach is described on a program-by-
program basis below. . .
POTW A Cost Recovery
-- ' " ' '• . '
• Charge structure: permit fee, discharge fee per gallon. Staff do not feel that
there are cross-subsidies between water and sewer users.
• IU surcharges: lUs do pay surcharges based on what they discharge.
However, ammonia nitrate is not included as a surcharge parameter, though
it does force the POTW to incur costs. In the past, both Zn and Cu were
parameters of concern relative to sludge quality.
— Surcharges were based on self-reported data. This facility had
, problems with a subset of lUs that, consistently under-reported
loadings. To address the problem, the POTW had to go in and
conduct baseline measurements. Follow-up sampling is conducted if
self-reported data appear aberrant.
* Lab fees: Only recently was a disposal charge added to the cost of lab tests
' , performed. They now do Ml cost recovery for all laboratory samples. Costs
are generally more expensive than contract labs.
- If the POTW requiresmore frequent samplingby lUs, the additional
- cost is usually enough for them to rapidly try to, solve the problem.
— The cost of surveillance sampling is not charged to an industry until
the POTW can identify who was responsible. Even then, the costs
. are often not charged back.
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POTW B Cost Recovery
, . " • " . ' '.7?'. • " '. . J' ' ..'''' .. ' ' • .'.•''...•. ' . " "*'•••: '' ' :':. . . '.':'• V ', ' ' ' i , ' . '','•. • U ', i V'i" li"' },'.
." ', • , •.•.'':!. ' • • •;!" .'.• r ' • .••.,• /,:\,"i, , i;;,;r ' •',:••' ." -..;•• ••' {- .;.• • - /'-''i" <;!''' ^'i'* s*'_j'' ••
This site 'had problems with its billing for inspections of lUs and associated lab tests. To
solve the problem, billing was transferred to the city's accounting department. Now, data goes
directly from the lab to the accounting department.8 •
» The billing for inspections is an average of all activity, and not based on the
number of samples or complexity of testing required. RJs are billed $ 146.50
per month, a fee that pays for 1'abcorsts and'pretreatmentr About 50 percent
' of the lab work is self-supporting through fees.
> • Fees collected go to the utility district. Pretreatment and lab funds are
budgeted by the utility and then approved by the city council.
• The pretreatment coordinator wanted to charge lUs the actual cost of
providing the service, but the accounting department said this would be too
complicated.
;•' -When resampling is required, the IU is billed an additional,$146, but the
actual cost of doing the sample is closer to $450.
• They have done a cost-of-service study for lab tests, but the results weren't
integrated into lab fees. If it were to be included, staff thought that the
monthly fee might increase, but the structure of the charges would be
unlikely to change. . .
• The pretreatment coordinator-feels" that higher charges would provide an-
incentive for improved operations. A proxy is the $500-$1000 fine levied on
restaurants for. oil and grease violations; this has proven more effective than
other types of legal action."
• The utility director is trying to develop better cost accounting data to help
bring their budget "under control."
'This system is also used to notify inspectors when an inspection is next required.
-------
POTW C Cost Recovery
Charges are based on flow, with surcharges on BOD and suspended solids; Any lab tests
performed are charged back to the IU, based on the average cost per test (with lower charges for pH).
Lab test rates do include the cost of staff time, plus a flat fee for sampling. lUs also pay a permit fee
and a one-time connect charge to the sewer. Staff doubt that industry is paying the full costs-of the
program, though they don't have enough information to evaluate it. '.''.
POTW D Cost Recovery
N • - . : . ' - - if ' -._.''
lUs discharging to this facility do not pay the full cost of the pretreatment program. The
pretreatment coordinator is not apologetic at all about this. The city benefits from the jobs and the
clean water the pretreatment program makes possible. In addition, despite the cross-subsidies, the
sewer rates are in the lowest 25th percentile in the state. They have an $84 million bonding capacity;
the debt is fully paid.
One of their users thought that the program's policy of not charging for testing and making
results available was an important factor in their being able to come into compliance.
POTW E Cost Recovery
This program doesn't charge for any sampling and analysis .costs, even if there are violations.
Charges are based on the volume of discharge, plus a surcharge for biological oxygen demand
(BQD) and suspended solids. There are no permit fees either. The pretreatment coordinator does
not think that increased fees on permits or IU discharges would translate to higher revenues available
to run the pretreatment program with; rather, revenues would go to the general fund.
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Cost-Accounting and Beneficial Reuse of Effluent and Biosolids
Sludge currently produced by all of the POTWs visited meets land application requirements
(though it is not all class A).9 In the past, metals have contaminated the sludge, and, in some cases,
upset the plant. The cost, of these events was, not charged back to the IUs, although some
enforcement actions are proceeding for the most egregious violations.
visited.
With plentiful water, beneficial reuse of effluent is not an economic issue for the plants we
INFORMATION SYSTEMS
There was a wide variation in the use of pretreatment information systems in the plants
visited There was universal recognition of the usefulness-of these tools, and some program staff
expressed frustration regarding their efforts to master existing software.packages (most notably
PCME). A number of the programs utilized information systems in a piece-meal, .non-integrated
fashion. This reduced the power of the systems to improve overall operations.
Improved Systems Would he Extremely Valuable
• One POTW conducts trends analysis by IU manually, by comparing test
results with historical data, they do not have a laboratory information
V management system (LIMs) system, but would be interested in one. The lab
director was concerned, however, that a LIMs would be difficult for a small
staff to manage, and that it would be difficult to conduct quality assurance on
sampling using the-system. ,
• ' Inspection reports are a large paperwork burden for inspectors at one of the
programs. Electronic reporting would be useful in helping the inspectors to
do their jobs better.
« One of the programs tried PCME, and felt that it had been useful in
developing annual reports. However, once billing functions were shifted to
the city's accounting department system, all reporting and record keeping was
done on an old mainframe computer (not compatible for PCME). They have
invested hundreds of thousands of dollars in this system, and are starting a
»POTW A had past concerns with zinc and copper, and is now concerned with nitrogen levels in
the sludge POTW Dnas problems wim^acteria and viruses. POTW B has had some problems
from the use of copper r~of control. POTW C has had problems with nickel..
5-24
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new round of programrriing soon. Nonetheless, they plan to scrap the.system
in 2-3 years for a Unix-based system. The program manager feels that the
. mainframe computer has been relatively inflexible to use.
.•.--' The pretreatment program is not billed directly for the large.
'-. pretreatment-prograrnming expenses the town has incurred.
Their ciirrent system does not allow them to search JUs of concern to
compare test results to allowable limits.
- " — " Queries can't be tailored to produce only data on IUs of concern;
rather, thick reports are generated.
One program finally got PCME to work after extensive experimenting. They
would prefer a user-friendly program, as well as one with continuing on-line
support. -
Another program uses a mix of computerization and handwritten forms.
They have a LIMs system for lab management. Most other functions are
h- computerized, with the exqeption of sampling reports for each IU: these are
written into manual forms and are visually scanned for non-compliance
(though the data are also entered into a computer). Report generation, record
storage, and statistical data processing (for the lab and the biological lab) are
heavily computerized.
One facility thought they might benefit from some of the programming
developed by other POTWs, but they would need good documentation. They
have done some programming relative to CSO management that they thought
other facilities might find useful.
-Use of Geographic Information Systems (GIS)
GIS systems are evolving slowly in many of the communities visited. They will eventually
provide a powerful tool to pretreatment coordinators, but this will take years to happen.
• One POTW has a partially completed GIS. The initial focus of the mapping
effort is on sewer infrastructure, although links to pretreatment are planned.
The GIS will also be extremely useful hi helping the POTW manage CSOs.
• Another POTW is. developing a GIS, also beginning with sewer
infrastructure. They plan to add manhole cover locations and sampling data
1 in the near future. ~
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A third POTW has just purchased the equipment to construct a GlS of sewer
infrastructure. While pretreatment applications are still a few years off, the
GIS will help the program to quickly identify discharges, and ease the effort
required to respond to' administrative tasks. The GIS mapping is being done
.within the POTW rather than using the city engineers, because the two
groups would not necessarily have the same priorities.
OWNERSHIP PATTERNS
Indiana POTWs have come under increasing pressure to improve the efficiency of their
operations, sometimes with the threat of privatization if they are unsuccessful. This has led some -
o? them tS begin to improve their cost accounting. Others have begun outsourcing functions
previously done in-house, or expanded their provision of services to surrounding areas in order to
bring in additional revenue.
• The mayor of one city gave the POTW two years to improve the efficiency
, of their program before he would evaluate privatization of POTW operations.
The POTW hired an environmental consultant to update standard operating
procedures and improve training. If privatized, the POTW anticipates that'
there would be less frequent sampling conducted.
" • Another POTW subcontracts billing to the privately-run water provider
•; (Indiana American Water Company). Underpayments are split equally
between water and sewer.
rahoratorv Operations
Laboratory functions have been outsourced, at least in part, by many of the plants visited.'
Generally riiore complicated analyses such as metals and organics have been outsourced, whi e
SSce^es remain in-house. This is not always the case, as two POTWs were extreme*
pr^ud of their laboratory capabilities.- One issue that got a good deal of discussion during the visits
was how to choose a good outside lab. .
'o One of these POTWs conducts all of,their tests in-house. They do not know if some tests would
bemoreeflectivelyoutsourced. In terms of technical capabilities, they feel ^™«£^
labs in the state. The lab is used only for internal samples; no samples from IU self-momtonng are
evaluated, as this wouldpose a conflict of interest, as well as be unfair to the pnvate labs.
5-26
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Outsourcing Decision. Pretreatment staff at one of the programs determine
which tests to outsource using a number of'considerations: the man hours
required to conduct a test; the wastes generated; and |he number of analyses
required per year in comparison to the associated equipment expense, All
organic analyses are outsourced.
Choosing a Lab. Choosing the proper outside lab is extremely important.
The lab director at this program requires a copy of the lab's Standard
Operating Procedures (SOP) manual, and will visit the lab. If the lab will not
send an SOP, or if pretreatment staff are not permitted to observe lab
operations unannounced, the lab is disqualified from consideration.
-- '', Once accepted, the lab must rneet a two week turnaround time; if they
fail, they are no longer used.
Few POTWs know how to evaluate outside labs and how to structure
workable agreements with them. This program does educate some of
. their IUs in this regard, but much more could be done, including the
preparation of "simple English" guide.
Lab Accreditation is Lacking. Another POTW believes that lab
accreditation in Indiana is lacking. Quality Control by EPA is done only
once per year, even though the entire pretreatment program depends on
accurate lab results.
Nobody has a "hammer" to force improvements in the lab.
EPA evaluations have had very long delays. For example, the results
of an evaluation done in April 1995 did not arrive until February
1996. This greatly reduces the usefulness of the review.
The lab director would like to see EPA tests done four times per year,
with results available within 30 days. This would also help to reduce
the impact of a piece of equipment happening to be out of compliance
on the day of the EPA audit.
Voluntary accreditation would be a good thing., even if the state didn't
make it mandatory.
POTW A sends metals to a contract lab for analysis. The lab has a 4-5 week
turnaround for sample results. This delay has created problems' for the
POTW in the past because they didn't detect nickel violations until they had
a plant upset.
POTW B does all of its testsyin-house other than total toxic organics (TTOs),
which it ships out due to a lack of space.
.'5-21
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I.* ;
— ; Lab is heavily utilized; nearly 50 percent of the tests they conduct are
not required by state or federal law.
This includes lots of monitoring of the, bio logical community in the
river. The program director thinks this should be required of all
• POTWs, since it is the key measurement of whether all of the
invested time and effort in treatment is working.
POTW C conducts ammonia, BOD, coliform, and phosphate testing in-
house. They used to do metals analysis in-house as well but the equipment
became unusable. They now contract put metals and organics.
> '; • . '" i .''.-,' „.' ; • i , • •' • , ' '" ;, • "nir1:' '•, •,
.' •;.,'; ;,';' ' ',. ' ;; ••„ •" ;'.-i / ;• , ", "> ; , •• . .-,.;.•, •;• ' ;,>:,! i . •';•. .•:.'...
— ; QA/QC information from the contract labs is required. Only after
quality requirements have been met is cost considered.
The pOtW also requires a lab that has been through legal
, proceedings and has proven the validity of its test results in court.
"In-Sourcing"
Common functions provided to outside areas by POTWs are sewage treatment, CSO
management, and sewer cleaning. There are sometimes problems with the interjurisdictional
agreements, affecting who controls pretreatment oversight .
• One site accepts flow from other jurisdictions. Surcharges on lUs are the
same as i those for industries within the POTWs normal service area. Charges
are billed quarterly, to the surrounding town ^^ rather than the discharging TUs.
While they do write the permits for these s, enforcement is a bit
muddy. Some of the Ills are not well characterized. Most of the
surrounduig areas have adopted this pretreatment program. .
- Staff did not know the flow that comes from outside jurisdictions.
Another facility serves about 6,000 customers outside of the city (versus
38,000 inside). This includes an industrial area in OH. They would like to
provide sewer cleaning services to smaller communities as well.
A third ^OTW visited took over m^
also serve an area 10 miles greater man me city limits. These outer areas pay
sewer charges, but don't pay the city tax. They don't want to become part of
the city for that reason.
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INDUSTRIAL USER ISSUES
Replacement of vapor degreasers with.alkaline cleaners at IUs has caused,
some problems with flocculation at the POTW. :
Vendors change the makeup of proprietary chemicals slightly, affecting, the
plating bath composition and sometimes the performance of the pretreatmerit
equipment. , .
RESIDUALS MANAGEMENT
Biosolids for all the facilities visited meet land application standards, although some also,
have old, contaminated sludge stored on their property, that didn't meet these standards.11 Key
issues associated with biosolids include when it can be applied, meeting the class A standards, and
improving the demand for this commodity. Effluent reuse is not a big issue since water is plentiful -
throughout most if Indiana.
• Timing of Application. One POTWs sludge land application permit limits
me amount of frozen ground application allowed. This creates problems for
marketing their sludge because farmer's are most open to sludge deliveries
during the winter, when compaction of their fields is minimized and there is
no interference with planting or harvesting. .
• Value comparison to chemical fertilizers. One of the programs visited is
planning to conduct a cost comparison between sludge applications and
•**'• chemical fertilizers at the end of this year. The results could help them
market they product more effectively. '
• Metals Levels Fluctuate. Sludge from one facility is being land applied, and . .
the quality is reasonably good. Currently, Lead limits have the least room for
increased concentration.-However, their metals values vary up and down,
suggesting their industrial dischargers do not have their pretreatment entirely
under control. In the past, they have had problems with Mb levels as well,
but were able to address the problem by sending letters to all customers with , ^
large heating or cooling towers. „- i
11 One of the programs has tons of sludge with high metals (from platers) stored near their plant.
This was from an earlier period where the pretreatment program was not effectively run. New
sludge meets Class A requirements, and will be blended with the old sludge over time.
5-29
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Commingling with Compost Administratively Difficult. Another program
doesn't commingle bioso lids with compost because it is administratively
more difficult. Land application is cheap:': about six cents per gallon of
sludge.
Biosolids Amendments/ "Enviro soil" is a sludge amendment that binds
metals so they will be inactive: 'One program thought that products such as
. this could help them to improve the quality and marketability of their
biosolids. ' , .
Effluent Reuse. Unlike California, water is hot in short supply in Indiana.
As a result, there is less pressure to reuse effluent. One of the sites does reuse
some effluent to irrigate a golf course; the rest is discharged to a full-use
stream arid into a reservoir. They are constructing a wetlands that will likely
receive effluent as well in the near future: . •
KEY FACTORS IN IMPROVING PERFORMANCE AT UNDERPERFOR>flNG
Options for On-the-Job Training
• Some small programs, such as one of the sites visited, must operate under a
compliance order with EPA. They often have few staff, and the staff they do
have are not always fully trained. While the order gives the program greater
leverage to make changes, it also creates difficult challenges for existing staff
to meet. Opportunities for 1-2 day training modules, or resources (such as
videos) that would be available for review on-site, would allow staff to
upgrade skills without taking substantial time off from the job.
Challenges for Smaller POTWs
• Meeting Pending NPDES Permit Renewals. Three POTWs are operating
; under expired permits. Some are not now required to have dechlorination or
conduct whole" effluent toxicity testing. Another thinks it might also have
problems with nickel limits under a new permit.
. • , "•!: " r •' • .- ' •• ' , ' ' ,; , . • ,.• -,,:i ' v ' -,v .: . , '• •;,:• ' •; ;
1 • • ' i i, , ','.''' '",'.'';
« Implementing P2. Requkes fairly high staff expertise and understanding of
options, and a substantial amount of outreach. Smaller programs don't
necessarily have the expertise or the time.
5-30
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Mass Based limits for categorical industries. Industries don't keep accurate
enough production records to allow the use of rnass.-based limits. Job shops
have enormous variation between flow and metals concentration as their
production runs change. Therefore, the.POTW often must reconvert these
mass-based limits into concentration limits.12
Ills Threatening to Leave, This is a critical problem for small POTWs in
regions with high unemployment. • For example, one industrial laundry has
lead exceedances and is threatening to leave if they are forced to comply with
the local limits. According to the pretreatment coordinator, the lead
discharges have no impact on the overall system, or on meeting allowable
NPDES or sludge limits. However, not everybody thinks strong
environmental requirements leads to loss of industry.
One program manager thinks that a good pretreatment program
. means an industry has a stable regulatory environment. Industries
can't afford not to have a strong pretreatment program.
-- An IU in this program felt that stringent pretreatment regulations
don't provide a competitive disadvantage, but perhaps provide an
advantage because other communities will be playing a game of
. "catch up" in the hear future.
Keeping permits up-to-date. One former pretreatment staffer of a facility
said that keeping permits up-to-date was a huge job. Very rarely would one
person at the industry have all the answers needed to do so.
The time consuming part was in measuring flows, verifying reported
information, and communicating with the industrial users, rather than
the mechanics of permit writing and modification. As a result, this
staff person did not think information systems and standard templates
would reduce the workload substantially.
12 Mass-based limits are often encouraged because they provide an incentive to conserve water.
One consultant (who designs and installs pretreatment systems), thinks that there are other factors
encouraging water conservation even without mass-based limits. Specifically, in areas with hard
water, each doubling of water consumption increases residual sludges (which are expensive to
dispose of) by one-third. . •; .
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SUMMARY OF SUGGESTIONS TO EPA
( a ' , f t , , , ,
Regulatory Flexibility
• Allow POTW to stop testing for pollutants that are not at an tU facility (e.g.,
cyanide or chromium).
• Encourage removal of metals from local ordinance if they have no impact on
the plant or residuals quality.13
• Iron -andi aluminum standards don't make sense, given the use of these
materials in wastewater treatment. •
• De'rninimis exemption for categorical industries would be very helpful. New
regulations, such as the Metal Products and Machinery (MP&M) standards,
will hit small industries that don't have the resources to deal with them.
Many of these small dischargers have no impact on POTW performance or
sludge/effluent quality. ' ' ,
• Standard reporting requirements for the many different EPA regulations
would make their job easier.
Faster response times on audits and reviews .
• In order to be useful, EPA needs to get information back to the POTW much
more quickly.
- Lab QC audit took ten months at one facility.
_. . Review of an enforcement response plan took two years in one
program.
In one instance, a locality did not recall ever receiving a report from
an audit (although EPA records do not support this claim).
13 Barium, silver, tin, selenium, and'fluoride were elirninated from one POTWs ordinance for this
reason. , _ ^ ' .'...••'..• " . ,•', ..; ,' ...'..,
: ;:: '• • , ' : • •'. ' '. • "'5-32 ' "..''•' ' ' '
-------
Don't Only Focus on Known Sources
• Find the new or unregulated sources in order to reduce loadings; don't simply
tighten standards on the "known" universe. ' '
Don't Forget Enforcement
• - One facility proposes tenaciously seeking out non-performing programs and
. forcing them to comply. -
SUGGESTIONS FOR THE CSI PROJECT
• Provide very short, user-friendly guides to sampling that: could be distributed
• . to the ZUs. One sampler felt as though self-monitoring samples were often
' taken incorrectly, rendering the test results inaccurate.
• Many people in the smaller communities fear that requiring compliance with
discharge regulations will lead to industries leaving town. To the extent that
EPA could illustrate why this is not the case (using examples from small
towns with high unemployment), pfetreatment coordinators could use this
information to their benefit.
- ,In one of the communities, an IU was fined $12,000 and forced to
clean up their process. They later said that they were winning
contracts that they didn't think they could have won if they hadn't
cleaned up their process.
• If a POTW is already way below its NPDES permit levels and have results-
based measures in place, EPA should allow them to do certain things that
might be considered "outside the envelope", such as allowing lUs to reduce
their testing frequency.14
*...'. EPA could educate POTWs about the flexibility that already exists in the
pretreatment regulations.
, l4 According to Pat Bradley, of EPA's Office of Water Permits Division, this can already be done because
a POTW can modify permits to IUs without EPA regional approval.
. - - - ' • 5-33 . " . - . " .'."• .' ' • • '
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ill 11411
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Attachment 6:
SUMMARY OF VIRGINIA POTW SITE VISITS, MAY 6-10,1996
SITES VISITED
Hampton Roads Sanitation district
* • ••:"*vri:,ii•.-.-. *..'•••*-•- • . •. , . • -, " - s ,
Hopewell Regional Wastewater Treatment Facility
City of Richmond Wastewater Treatment Plant • ,
Alexandria Sanitation Authority •
Interview Team: Patrick Bradley^ OW; Wendy Miller, OECA; Doug Jamieson, OECA (for Hampton
Roads and Hopewell); Doug Koplow, lEc.
The Virginia facilities differed from those in California and Indiana. In Virginia, no programs
had experienced recent enforcement action, although some were definitely struggling more than
others. An additional difference was a wide range in the level of industrial discharge, from a low of
two percent IU flow/average daily flow to a high of 80 percent. The POTWs varied in the
complexity of operations, from a small geographic area with a singleplant, to a large geographic area
with a multi-plant network. While many issues were similar across these facilities, the diversity of
facilities raised some interesting issues that did not surface during the first two trips.
NEW INSIGHTS FROM THE VIRGINIA VISITS
• The POTW as an informational resource remains a critical factor in IU
compliance As in IN and CA, POTWs with effective treatment programs
have become an informational resource for HJs to turn to when theyhave a
potential discharge problem. '
« Interjurisdictional agreements often fail to give the pretreatment
program the leverage it needs to control contaminants in influent. Some
programs we visited received discharges from industries outside their
'•".".• districts. While generally there were agreements-with me municipalities
where these industries were located, sometimes these agreements were
inadequate.
• ' " , • - ' , f - • - .
• Operating a network of treatment plants provides additional flexibility
to operators, but also creates additional challenges. One of the programs
we visited manages a network of plants, many of which have cross-
connections to allow flow diversion. Initially, communication between the
interceptor staff and plant personnel affected by diverted flows was
' ' ' ' " •" .'...' '. 6-1 •'.'. ' ~ -
-------
inadequate, causing operational problems, By requiring pre-notification to
plants for any diversion, these problems were solved. Another complication
of a multi-plant network involves setting charges and discharge limits. Since
" the plants have different discharge points, cost structures, and IU profiles,
choices on allowable discharges and pricing have important implications on
where new IUs locate and how much they invest in pretreatment.
Serving military customers creates substantial challenges! One Virginia
POTW receives a significant flow from military customers. Even though the .
Clean Water Act (CWA) does not allow the military, to pay fines for
"discharge violations, the POTW should assess them anyway. Assessing fines,
even if they are uncollectible, is an effective enforcement measure because
of the military officer's concerns that the resulting adverse publicity might
harm his or her prospects for promotion. Other effective tools include
enhanced education and suspension of service until stipulated conditions are
met. ' .•.',;,. .•-,,, ; ., ,',,„," ' .' . .'. .'"
.Partnering between city managers and industries creates opportunities
and challenges. To promote economic growth and protect the environment,
• one POTW established very strong contacts with large industrial dischargers
and city managers. The coordination gave them opportunities to jointly
resolve problems, but many checks and balances had to be built into the
system in order for the public to trust the arrangement
Don't require pretreatment where effective centralized treatment
already exists. If a plant can handle a specific industrial discharge, the EPA
should not force pretreatment industry-wide for that material. The net result,
rather than improved environmental quality, is that industries will stop
discharging to the POTW, leaving it underutilized and expensive for the
remaining customers.
POTWs built to serve primarily industrial customers address important
public policy issues regarding pollution. The EPA's "polluter pays"
- principle strives to make industries responsible for the full cost of controlling
emissions; and tries to ensure that the price of their products adequately
reflects the associated environmental harm of production. Two of the
programs visited in Virginia used some public funds (either EPA grant
money or tax-exempt municipal bonds) to construct waste water treatment
plants serving primarily industrial customers (though both also serve some
residential customers as well). While in both cases the industries also
. contributed funds, the cost of. water pollution control was, in effect,
subsidized by public taxpayers. While it may make sense to share
infrastructure between municipalities and industries to take advantage of
'•.•*'.': , ' • ,. ,.'.'',.'-.:., . , ".. v , • ;' 6-2 "' " '' •
-------
economies of scale, EPA may want to be sure that industrial .raterstructures
recover these subsidies from industrial customers' so that the industries pay
the full cost of managing their pollution. It should be noted that these
subsidies are likely to be small relative to the other inducements local ..
governments build into the municipal tax structure and use to lure new
industry. . • '• . •
Pretreatment is sometimes seen as peripheral to plant operations, rather
than central to it. One pretreatment'Coordinator-expFessed'feistrati©n that
the plant operations 'staff did not see the importance of pretfeatment in
ensuring continually-solid plant operations. He thought pretreatment should
drive plant operations, not vice versa. • • . •
Politics influences ability to meet pretreatment program objectives.
in Indiana, politics remained an important issue in pretreatment performance,
but one that was difficult for program coordinators to speak openly about.
Problems tended to be worst with strong, politically-connected firms.
Political influence was brought to bear in the areas of whether or not sewage
treatment would be provided and the economic terms of that service, as well
as the area of enforcement for violations that came out .so clearly on the
Indiana trip. , : ,
MOST CRITICAL FACTORS IN RUNNING A SUCCESSFUL PROGRAM
1 As-with California and Indiana, many critical factors in running a successful pretreatment
program were the same. ' .. ' ', .
• Regular communication with, and visibility to, the lUs. Programs that
maintain frequent contact with their dischargers have developed a working
relationship that supports early problem identification and are tools for rapid
solutions. One program shows up unannounced quite frequently. However,
since the KJs know they will be treated fairly by the pretreatment staff, the
frequent visits support rather than impede the working relationship. Another
gets weekly reports from its (albeit smaller) group of SIUs, and holds
monthly meetings with environmental representatives from the lUs. :
• Establish individual accountability for performance of IU pretreatment
units. Frequent contact with lUs is one method of establishing
' - accountability. Another method employed by one of the programs,is to set
up regular public meetings between the citizens and the SIUs to discuss
environmental performance, including wastewater treatment. This same
6-3
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program has the home phone numbers of every environmental manager at the
SIUs, and calls these individuals any time there is a problem. This creates
very different responses than holding the company in general responsible.
Ensure technicaK competency in IU pretreatment staff. Without
• technically-competent staff at the IU, it is much more difficult for the POTW
to control the quality of effluent. RJs must have the ability to detect and
control probiems quickly. Sinee this competence is highly dependent on the
personnel in charge, one of the programs requires the slug plans of each IU
to be updated any time there is a change in pretreatment personnel. This
requirement gives the POTW indications of when there might be staff-related
problems in the operation of the pretreatment equipment.
Balancing enforcement and education during inspections. As with the
CA and IN trips, this was a common theme in a number of the Virginia
progratiiS. Programs have long-term relationships with many the staff at their
TUs that help them to achieve compliance. One of the pretreatment
coordinators went so far as to define his program as successful because they
can easily communicate with the industrial dischargers and are notified as
soon as there is a problem at one of the plants. To him, this was a more
important indicator of good performance than measures such as the number
of NO Vs or industries in SNC.
1 ' .''' ' ' '""; '• •' \ '"'','• " • , v • n •''"
Political support is important. As in Indiana, political pressure was
sometimes brought to bear on program staff to influence the direction of
activity or enforcement. Some of the programs felt that they did not have
complete support from their utility-district, city, managers, or city attorneys
to enforce the Clean Water Act, even against large industries. This
undermined the ability to do their job, and created a more difficult working
environment.
Federal enforcement is a good thing. A common feeling on the part of the
pretreatment programs was that strong enforcement was sometimes the only
way to get the resources needed to adequately run a pretreatment program or
to overcome political pressure from industries of local, politicians. One
program stated unambiguously: "EPA enforcement will turn programs
• around." This response echoe's perspectives we heard in both'CA and IN.
Have direct oversight for all its A number of the programs we visited
accepted discharges from industries outside of their districts. -While there
were generally agreements with the municipalities in which these industries
were located, these interjurisdictional agreements (UAs) were often
inadequate. In some cases, the pretreatment program did not have the ability
' •• . '; 6-4 ' , .. . , , .. ' .
-------
to inspect these discharging industries, could not levy surcharges directly on
.them, and could not work freely to verify discharges and identify unreporfed
discharges in the area outside of their area of primary domain. Where
reporting was required, the notification process regarding discharges or,
violations from the surrounding municipalities was sometimes far too slow.
Some of the POTWs actually have an IJA with a surrounding area that in turn
has an IJA with the municipality in.which the HI was,located.,, This dilution
of oversight power greatly diminishes the leverage that the plant actually
treating the wastes has over ensuring that discharges do not cause operational
problems or NPDES violations. Where the IU in question is also large and
' politically powerful, pretreatment leverage declines still further.
A credible threat of enforcement by POTW is a necessary tool. Two of
the programs, did not have the delegated authority to take civil enforcement
action against violators. Rather, civil action had to go through the .regular
city bureaucracy, where it would be subjected to the many competing
interests of other departments, greatly reducing the POTWs ability to induce
rapid compliance. '.
Consent agreements with suspended fines work very well. As in Indiana;
a couple of Virginia facilities noted the power of consent agreements with
financial penalties which kicked in if the industry didn't comply on a
stipulated time schedule. These agreements seemed to provide a strong
incentive for rapid correction of problems, and allowed funds to be.applied
to long-term solutions to the environmental problems.
IDENTIFYING INDUSTRIAL USERS
The POTWs in Virginia used similar methods to identify new industrial dischargers as were
- applied in CA and IN, ranging from phone books and communications with other municipal
departments, to drive throughs of industrial areas. Some of the VA programs even tracked
unregulated industries if they felt there was a potential concern that discharge from these industries
could affect the plant. In some cases, the POTWs plan to extend regulation to these sectors (e.g.,
photo processors) in the future, although doing so may require modifying the existing sewer
ordinance.
One program in particular*was unhappy with their inventory of industrial users. A survey
done in the 1980s identified 200 potential RJs (including dry cleaning and radiator shops). They felt
that a major area of weakness was from lUs located in surrounding areas with whom they had an IJA
but not much direct access. This program felt that they had fairly good communication with other
municipal offices within the city (such as being notified of new water hookups and large water
• . ' • ' -• " '-• , '6-5' -•-..' , ' • '
-------
consumers), but few links to information on new businesses or water hookups in the other
jurisdictions. For example, the program does not even get sent a copy of the sewer connect lists
from the two.adjacent counties that discharge into their sewage system. The pretreatment
coordinator is anxious to complete a survey for specific commercial uses to identify unknown
facilities.
SAMPLING AND INSPECTION STRATEGY
. A number of familiar elements came up on the Virginia trip, as well as some new issues that
the programs have creatively tried to address.
• Rotating Inspectors. A theme that came up in visits to other sites was
echoed by an inspector in Virginia: rotating which plants you visit is
important because it's "hard to stay focused when you inspect the same plants
year after year." There remains a balance between familiarity with a specific
plant and its personnel and retaining a fresh, inquisitive view of the
' .'•: ; inspection process. .
• Good relationship with Ills makes inspections non-adversarial. One
program said that its industries didn't mind being inspected because they had ,
a long relationship with the POTW and its personnel, and trusted that the
program would treat them fairly;
• Frequency of Inspection. One plant said that it does not conduct annual
inspections at each IU because this was not necessary and the program did
not have enough resources to do so. Since the Clean Water Act requires SIUs
be inspected a rninimum of once per year, this comment seemed strange. On
"further examination, this facility did "audit" the lUs more frequently, but
viewed an inspection as a much more detailed undertaking. It may just be a
matter of semantics since the regulations do not establish what an inspection
must include. ' . ,
i | , n ' : ' . ' ' • i i! " i ' ' .,-',,
_- Inspections, as defined, would require about 1 week per SIU. This
time was broken out as follows: one day to review files; one day to
review and assemble relevant data on me plant, .one day to visit the
plant (2 days if.the plant is new), and one day to write-up the visit and
ask for additional information.
— At this particular plant, only one person conducted the full
inspections. In addition, they had very little in the way of
information systems that would Have made file review and data
, review and assembly much easier.
.6-6
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The STUs in this particular region conduct substantial self-
monitoring, and report on a weekly, basis. Because SIU discharges
have large financial ramifications for the industries (they share plant
costs on a pro-rated basis), many parameters are tested every day.
This frequency increases the likelihood that any problems in the Ill's
processes will be detected early, and reduces the need somewhat for
frequent external inspections. . •
Many of the large SIJJs in .another district are also required to sample
daily. Better compliance leads to reduced monitoring requirements.
Sampling and Inspection of POTWs is inadequate. Many of the programs
mentioned that they did not think the Virginia DEQ did a good job
overseeing the state's delegated pretreatment program. One program.
coordinator has not had a full audit since 1981. While the DEQ would visit
once per year to review the program, they did not do a full program audit, the
type of multi-day review that would provide program staff with useful
information on ways they could improve. .
Time of travel data useful in detecting source of slugs. One of the
programs has modeled their interceptors to estimate how long wastes take to
flow from one point to another. This makes it easier for them to trace back ,
discharges, and to prepare other plants in their system for diverted slugs.
Testing points at the bar screen and lift stations also help identify and trace
unknown discharges.
Sampling at military facilities requires different strategies. One facility
has a substantial number of military dischargers. Some of these dischargers
tried to restrict pretreatrnent staff from entering their facilities because of the
top secret nature of their operations. The POTW took a hard line on this:
their staff required entry or the military would not be permitted to discharge
to their plant. The POTW was willing to have its staff go through security
clearance, so .long as, in the end, they could inspect unannounced as
necessary. •',
Municipal permits offer an alternative to interjurisdictional agreements
where inspection is a problem. One program, faced with restricted
oversight of industrial discharges entering its system from another city, used
a municipal permit to solve the problem. This permit simply allows no
industrial discharge from the other city. The POTW .can stop regular service
6-7
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1 *
to the other jurisdiction if it detects problem discharges. This provides a
relatively strong incentive for the other district to adequately monitor its own
industries.1
Refusal to split samples with IUs^ One of the programs says it does not
split samples with IUs, because doing so has been problematic, with certain
SltJs in the past always splitting the sample and challenging the results.
Since this program does not have penalty authority, -the costs' of allowing
splitting outweighed the benefits.
Expanding Oversight to Include Direct Dischargers. One program in IN
felt that their success in protecting environmental quality owed a great deal
to their ability to inspect and regulate direct as well as indirect dischargers
affecting the wafer quality in their receiving waters. The one program hi VA
that we discussed this with thought that this approach made a lot of sense, but
was-wary of being given large new mandates without the necessary additional
funding.
ENFORCEMENT STRATEGY
Causes of Non-compliance ,
Most program staff felt that'their IUs wanted to "do the right thing" with regard to
minimizing the impact of their discharges on the environment. One program felt that non-
compliance among metal finishers was an issue of expertise rather than malice. Another noted the
importance of well-trained staff. In this district, problems often occurred when the one dedicated
pretreatment operatofwent on vacation.2
' • ' '," ' • " , ' ' •. • , .,'•'••'
A Lack of Penalty Authority Weakens the Program
«, ' ,, . , . • ', 'i
Programs that are unable to levy financial fines have little leverage to force recalcitrant
industries into compliance. In Indiana, a couple of programs faced pressure from their utility
managers or boards not to fine violating industries. In Virginia, a new constraint existed: a lack of
legal authority. The impact of this constraint is the same: less leverage to improve IU performance.
.I 'While this approach is contained'in the EPA model sewer ordinance, the pretreatment staff
did not think it was applied very frequently^ ,
2 One implication of this finding is that IUs should have a plan for backup responsibility.
, - , - , -. :: • -• • ' /.'..' 6-8
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One program that does have this authority illustrates its importance. The program has recently
begun issuing fines more often than it used to, making fines automatic in certain circumstances.
Pretreatrnent managers have noted that firms have been getting back into compliance more quickly.3
Two programs had local laws that did not give the POTW penalty authority. One used back
charges for enforcement sampling as a way to force Ills to incur some costs, but this approach did
not allow for a large financial impact (with maximum charges of about $2,500). Larger fines could
b£ brought only through formal litigation in the judicial system using the city's attorney.
Unfortunately, in "an apparent blatant conflict of interest, this attorney sits on the board of the biggest
IU in the region, and therefore doesn't want to support the cases, especially against this firm. The
pretreatment coordinator has resorted to the "nuisance factor" to promote compliance, calling
compliance meetings at the sewer authority and requiring upper managers of the violating TUs to
come. This approach has worked to some degree. The coordinator of the other p'rogram remarked
that the lack of penalty authority greatly weakened the power of consent agreements, since such
agreements could not have the financial penalties associated with missing stipulated deadlines
commonly put in by other POTWs. Adding this power would require changing the city charter, but
the city doesn't want the POTW to have this ability and is unlikely to make the change.
Another Virginia program regulated a number of military dischargers. Under a special
exclusion in the Clean Water Act, military Installations cannot pay fines due to sovereign immunity.
Thus, this program is also unable to collect fines. This program has creatively used the fears of
military officers regarding how adverse publicity will affect their careers to ensure responsiveness
on the part of the installations to water quality problems. Interestingly, this program assesses the
fine and publishes the amount even though it can't collect the funds, as an added component of the
use of public pressure.
Stringency of NPDES Permits Drives Enforcement Strategy
Since a POTW is judged in large part based oh its compliance with its NPDES permit,
actions taken against lUs are often derived from the stringency of the permit. Virginia provided two
extreme examples of this point: -„
"'•,'" ' " '''•*•-"', ' • "
• One program has extremely strict discharge requirements for certain
constituents," and has had to regulate even minor industrial users such as 1-
hour photo labs m order to comply. TTiey have been successful in this regard
by conducting a large amount of outreach and by working with the trade
associations. ' . ,
* 3 Another, program visited in VA also had penalty authority and made frequent use of consent
agreements with suspended fines. This pretreatrnent coordinator noted that technique worked^very
well, and that it was always difficult to figure out what to do with the fine money anyway.
6-9
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Another program has'an IsTlDES permit that expired five years ago (and is
therefore less stringent than the newer ones), and a very low contribution to
flow from industries. The biggest contributor of discharges of concern are
small shops, but any single one has minimal impact on the overall system.
This program does not face the same pressures to regulate industries as the
first case.
Reward the Positive as Well as Punishing the Negative
• One of the programs has an awards program for industries that have superior
compliance records. Program managers felt that this was an important
1 • incentive for the industries (and military commanders) to do as good a job as
possible with their pretreatment.
• Another program would recognize lUs as exemplary if they went all year
without a violation. ,
* Enforcement Actions Slowly Escalated
A range of enforcement responses has been noted as a useful tool by a number of programs.
One Virginia program actually uses a point system, with more serious and/or more frequent
violations earning more points and a more severe enforcement response. Monitoring requirements
also vary by IU, based on their assessment of need. The program tries to work out cooperative
agreements when there is a problem before shifting to more adversarial approaches.
Theresisnot universal agreementon whata substantial violation is, however. The primary
§rea of disagreement is reporting violations, with many programs (in VA and elsewhere) treating
paperwork violations as insignificant. However, one VA program, questioned this assumption. The
pretreatment coordinator felt strongly that timely reporting is an important part of compliance for
an IU, because it can greatly affect the ability of the POTW to quickly identify and address
problems. Therefore, he did not have any problem putting somebody in SNC for reporting
violations! ' .',.',.' ',".." ', ' .. '. , •. . • , .. . ' '.'. ,',", '''''.'•'-'' •"'
Another program felt that paperwork violations were not worthy of much action, they
wanted the focus of.enforcement" to be health and safety, and did not ;see a connection between
paperwork and improved health and safety. This same program viewed a pattern of lapse, improve,
lapse as particularly serious, because it suggested the IU did not take their pretreatment responsibility
seriously.
6-10
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Multiple Enforcement Units of Different Stringency Can Cause Problems
Both^the CA and IN trips brought out the transitory conflicts between the POTW and other
direct dischargers, where firms discharging into the POTW faced more stringent requirements than
.the direct dischargers, even though both used the same receiving waters. One of the VA programs
had a new angle on this issue: some of the IUs it serviced discharged a portion of their effluent to
the POTW, and a portion directly to receiving waters. In this 'situation, the state did not enforce
NPDES permits as aggressively as the POTW enforces its local limits. Thus, facilities regulated by
both the POTW and the VA DEQ sometimes resent the; POTW in comparison. This makes it harder
for pfetreatment staff to work with these particular plants.
Public Oversight through Meetings and Information Sharing "
The Toxic Release Inventory demonstrated how powerful public disclosure can be in
encouraging sound environmental practices. Following a large chemical accident in the early 1970s,
one of t^e VA facilities visited had to devise a way to retain its strong industry base while
simultai.. jusly reestablishing public trust that the city government could protect the health and
safety of its citizens.4 They devised a host of mechanisms to establish accountability and rebuild
public trust: . . -
• Public Meetings. The large IUs in the town meet with the City Council in
open meetings to provide the city with information on their production and
discharges. There
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Information Dissemination. A. variety of detailed information on the
industries, discharges, and any accidents, is provided to public quickly using
^ internet and a system of telephone information lines, where citizens can
dial indifferent extensions to get information on particular topics.
City Safety Office. The city has established a' safety office as an information
source ifpr citizens to help them understand the technical aspects of lUdata.
The safety office will also act as a go-between for the citizen" and the IUs, to
help citizens access information.
Third Party Verification. The state of Virginia has offered to provide
additional information to local citizens and to oversee that the information
presented to the citizens by IUs and the POTWs is accurate.
Although there are two local environmental groups^
opposition to the plant or its SIUs. The plant personnel credit their extensive safety/outreach effort
"for this. .......... '" ........... .".' " .''..'•" ' ' ' " ..... ..." •'•"•.'"•' •" ^ ...... '"•'
TUs Sometimes More Difficult to
^le technically sophisticated industries are able to purchase and operate^retreatinent
they met the letter of the law while violating the spirit (and. increasing loadings to the system).
Compartmentalized Dischargers Cause Problp"™ 'far Regulators.
Large, compartmentalized dischargers, such ^
staff Responsibility for hospital discharge may be fragmented, even though all the flows end up
at the PO?W Thul identifying the cause of a problem or the best method to have it corrected is
more difficult.
6-12
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Obtaining Compliance for Small, Non-Categorical Dischargers
As was common in California, some of"the VA POTWs required installation of certain
recovery equipment to prevent problems at small non-categorical industries such, as photo
processors. However, these programs have some problems with shop's that don't properly maintain
the systems. , , . . - ,
POLLUTION PREVENTION
.''••."- •'••'', • ; •
As in Indiana, most pretreatment programs felt that pollution prevention was a good idea,
but ensuring their lUs were in compliance was a higher priority. One program also felt that P2 was
likely a "tough sell on a cost/benefit basis." The pretreatment coordinator said that P2 was unfunded,
and probably unfundable. The large Ills, he said, were already implementing on their own, due to
TRI and Chemical Manufacturers Association (CMA) goals. Their technical knowledge was far
beyond that of the POTW staff. He thought that broader application of P2 (i.e., by smaller
industries) was unlikely to have much positive impact on plant operations or residuals quality; A
local household hazardous waste collection program was classified as "costly with intangible
benefits." \ , ^ ,
Another program stated that their inspectors were not that well versed hi P2 alternatives for
their ITJs. They thought that their current access to detailed info on P2 was not great, and that it
would be very useful to have an on-line resource center with this information.
EMPLOYEE ISSUES ,
'.'"'•' ••*•'' ' '. , . "'•'•• " • , • ;
" Keeping the job interesting remained a key employee-related issue in Virginia as in the other
two states. Staff retention was an important component of an effective program, since staff
understood their programs, knew the lUs, and built up relationships that made them effective
regulators over a period of years.
Staff retention at the VA POTWs has been relatively good. One program had very long staff
retention, generally over 10 years. They attributed this to a fair program for staff (i.e., not every
minor situation is written up), salaries at the upper-end of the pay scale, good benefits, and
. preferential promotion from within. ^ ..-'",'.
Another program feltthat while its staff retention was relatively good, the costs of training
new staff (both direct and indirect) were so high that they wanted to improve retention even further.
m contrast, a.third program had relatively high turnover* with a staff tenure of only about two years.
The pretreatment coordinator thought this was due primarily to low salary levels and numerous,
higher salary opportunities for their skills. He did not see an easy solution to increase retention.
6-13
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As In Indiana, some of the programs made an effort to restructure their employees to provide
;,; better overall service to customers while also making the jobs more interesting for staff. The best
: example of this was the development of cross-functional workgroups by one plant as part of a total
quality initiative. Departments meet as a whole, and then form workgroups to address issues brought
up at the departmental meetings; an effort is made to mix functional staff to solve these problems.
EPUCATIP^^ ^
Staff training was an important aspect of staff1 retention, as well as improving the expertise
of program managers. Pretreatment staff sounded some familiar themes in- this^ area, as well as some.
riew issues; The training challenges facing small programs was clearly delineated by one program
rnanager aS follows:
Small programs don't have enough funds for anything, let alone training. The state
used to go out and reach this audience, but has cut way back. Even at Virginia
Association of Metropolitan Wastewater Authorities (VAMWA) meetings, the big
programs show up, the little ones don't. Small plants are the biggest problems -- they
may not even have VCRs on which to watch a training video. :
This program viewed certification of operators as one solution. In their view, certified lab
technicians and WWT operators would go a long way to improving compliance at the smaller
programs by ensuring a minimum level of competence at both the POTW and the IU.
Training Budgets Sometimes Limited Training Opportunities
One of the smaller programsifelt that their training budget was adequate to meet their needs;
howeverritey were located close to a major city, and therefore had low travel costs to attend the
variety of training activities held there. Other programs had training budgets that covered training
fees but didn't cover travel costs, and therefore were of limited value and restricted them to the local
• area. This; theme was mentioned by a number of programs on other trips as well, demonstrating the
importance of local training options and the problems associated with federal budget cuts in this
ark; The result of the lack of funds or restricted funds, in conjunction with high daily demands on
the staff at smaller programs/was that the bulk of the training occurred on-the-job.5
5One of the pretreatment coordinators wanted to prepare a complete step-by-step manual
for the program as a way to make the on-the-job training easier. .
' " : •' ." ." •'.'• ,' ' 6-14 .: . '. ' ' • ';
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Views on Written Training Materials
Ken Kerri Training Manuals Again Highly Rated. The Ken Kerri
guidebooks (sponsored by EPA) were once again mentioned as important and
valuable resources.
Other Useful Training Materials.
One program mentioned that the Industrial Waste Primer (Austin,
Jack Gatlin) and Streamh^e (from'St. Louis) were both useful
Another program taught Ken Kern's California State University
(CSU)self-study course on "Pretreatment Facility Inspection" once
in-house. ~ '.'-..'
EPA Guidances and Manuals.
~ EPA's sampling and inspection guidance was good. The ERP manual
was not as good because it had too many "cookie cutter" plans.
Preventing slugs and interference guidance was worthless.
Treating trucked wastes was extremely confusing.
A number of older guidances are still very useful, including
"Establishing a Pretreatment Program," "Permitting," and "Model
Ordinance.". .
EPA should update the local limits guidance and the environmental
criteria (plant inhibition data).
EPA's internal methods manuals or guidance memorandum also
•; useful. ' ' , , T
-=•-.' EPA should have all of its guidances available on PIPES.
Seminars. Trade Associations, and Local Pretreatment Groups
• National Trade Associations Are a Useful Resource. Programs continue
, , to rely on WEF and AMS A for training materials and information. One
program especially mentioned the AMS A Pretreatment and Hazardous
Wastes Committee as a good information sharing resource.
• Virginia Association of Metropolitan Wastewater Authorities
(yAMWA). This organization has the potential to be a strong regional
resource. However, some of the pretreatment coordinators felt that
pretreatment was getting ignored by the group. One program coordinator
hypothesized this was because the plant operators didn't want pretreatment
-------
,:„:: to focus on problems at the plant that might cause action by EPA or the state.6
• rji" However, VAMWA has organized inexpensive," local workshops that
' provided access to training for smaller POTWs that might not otherwise have
. been available. Topics have included sampling and inspection.
• Are there Other Programs Like VAMWA? One of the programs felt that,
- VAMWA was a powerful initiative because ft was willing to. take
responsibility for bringing training to a more local level. The coordinator
wondered if similar initiatives existed in other parts of the country.
, • Training Courses. One of the larger POTWs recently hosted (with partial
EPA 'funding) a P2 training course by SAIC that they felt had been useful.
PIPES Needs to Plav a Central Role in Disseminating Training Information
• PIPES needs to meet a broader range of needs. Programs generally felt
that PIPES'was an extremely valuable resource, and one that should be
developed into a much more effective communications tool that it currently
was;
PIPES needs to be more user-friendly and consistent.
A user should be able to view information on-line before
downloading to be sure it's what they want.
PIPES would be a very useful resource to them, but they don't
currently have on-line access in their program.
PIPES is a very good resource but all EPA guidance should be
available through it.
Unmet Training Needs
Skills. Improved communications and investigative skills for inspectors.
Learning to do good inspections is the most difficult part of the job.
Cross-Training. One program felt strongly that all POTW employees
should understand all operations of the plant, including plant operations,
• laboratory operations, and pretreatment. Even if not experts, they should
VAMWA does have a pretf eatment committee.
I|::I:E,!, „ ... , i"., • ' , • i ' a- - ••""„: i. > ' " ' ,. ' ',"".,,,,
."'I'" ' .:, '• •'•; '.. ' ..•: ',,6-16
>,„ :* /,'" ;*« , irs
-------
have a general understanding. 'The program said they are working in this
"direction through "cross-crafting" (cross-training) employees1, but that it was
a slow process and most staff remained specialized. ..-. -
* , • • ' t ' )'
Videos, Industry-specific videos would be useful. A training video would be
good for both pretreatment staff and Ills. Videos of value include sampling,
flow, meter measurement, and inspection of GIUs (one per CIU category).
This support for videos was not universal; one program thought they would
not be useful, because inspectors need to learn by accompanying other
inspectors on site visits. Videos could not substitute for the very important.
role that on-the-job training provided.
Pollution Prevention. Easy-to-understand guidance on P2 is .needed to
inform lUs and commercial dischargers. Most lUs have a tough time
understanding pretreatment requirements in general unless they have an
- environmental manager. *
Local Limits. Additional guidance on technically-based local limits would
be useful. . , " ,
Regional Training
A number of programs felt that training support by EPA Region 3 had evaporated, and that
more input was needed. This regional presence is not consistent across the country. Each Region
approaches training differently, and focuses on what they feel are priority areas for their Region.
At the very least, these programs wanted to be made aware of training that was going on in
the region already. Pretreatment staff named a couple of examples of where Region 3 programs
were poorly advertised, and others where they didn'teveh know about it until after it was gone. They
supported the concept of creating regional calendars on PIPES allowing local and regional training
to be publicized to other programs quickly and easily. .
OUTREACH
Outreach programs varied by POTW and local needs.
• Targeted industry efforts. One program has initiated outreach for the ship
1 repair and printing industries, areas of concern in their district. They also
began an outreach program for P2 in 1994, run jointly with- their public
relations department.
6-17
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Structuring IU Reporting. One program was having difficulty getting
accurate and consistent data.from, their lUs." To .address the problem,
pretreatment staff developed "nbtebpoks". to help educate the'IUs and
improve their reports. The notebooks contain the sewer ordinance, the
enforcement response plan, a list of abbreviations, 'and relevant P2
information" In addition, the notebook contains facility-specific information
such as a permit application form, a copy of the Ill's permit, a fact sheet on
the program, sampling results, and pretreatmeht system plans.
Outreach to other parts of the POTW is important. Letting other parts of
the WWTP and the municipality know about pretreatment arid its important
role in protecting plant quality helps garner support, for pretreatment
activities. The degree to which programs did such outreach varied. For
example, one of the smaller programs felt mat other departments knew about
the pretreatment program, but not much. While the coordinator felt that there
wks support for the program at upper management levels, the coordinator's
reporting line was quite indirect, with two or three tiers to go before upper
management. Often, such a reporting line suggests a reduced view of the
importance of the pretreatment position in the eyes of upper managers.
Outreach to the lUs driven by past incidents. One of the programs visited
had extensive outreach due to a significant environmental accident in the
1970s at one of its SIUs. The POTW set up a number of committees and
systems to oversee SIU operations following the accident.
— ' Technical Advisory Committee: reviews potential projects, and shares
information among major industries. Each industrial partner has an
environmental liaison that sits on this committee. Also deals with
budget issues. .
Environmental Liaison Program:' has monthly meetings to address
' ehvironmeritai issues, and includes environmental representatives
from smaller dischargers
Industrial Community Partnership: Works with community on
issues of concern.
According to pretreatment staff, the frequent, informal contact and
communication with Ills makes enforcement easier.
EPA outreach to programs needs improvement. There have been a
number of instances during the visits where the POTWs misunderstanding
the regulations or not recognizing flexibility that exists has led the POTW to
regulate industries that have no impact oh their treatment plant. For instance,
one POTW on the Virginia trip was regulating a seafood processor as a SIU
'"' '' ","," " ." :' "'" • '.. , •' 6-18" \ ' .' " '. -. , ' '. ' , '" :' ! "
-------
because it had a flow greater than 25,000 gpd. Thfe POTW wanted to stop
regulating the seafood processor, but did not think it was allowed to because
of the 40 CFR 403 regulations. This was not the case; the problem they faced
was that they wrote their local regulations in such a way that they did not
provide themselves with the flexibility available in the federal regulations
EPA education of public with regards to pretreatment needs
improvement. One program coordinator felt that EPA gave a great deal of
publicity to sewage treatment in general (such as at Earth Day celebrations),
but rarely publicized the role of pretreatment in the sewage treatment
equation. , ,
PRETREATMENT RESOURCES AND COST ACCOUNTING
i '-• • - .'.,'-• , ' • • .''•''-."
As with the other states visited, programs in Virginia had a wide variety of budgeting
approaches and varying degrees of sophistication with regard to their cost accounting systems.
Budgeting
IUInfluence. One of the programs has its SIUs on their board, and vote on
the budget for the plant. While the city council (on which the SIUs do not
sit) has veto power, this structure poses potential conflicts of interest.
Because the SIUs at this particular plant are de facto equity holders in the
facility, they can be expected to make more financially responsible decisions
than if they simply discharged to it
• ' . ' ' \ . ' ' _ _ ,
Budget Size. The programs have a wide range of financial support for
pretreatment, ranging from $150,000 per year to $2.5 million. Lab costs hi
the first program represented 1/3 of the budget; lab costs in the second
program represented 50 percent These budgets do not always represent the
total resources available for pretreatment; for example, the smaller of these
programs pays computer costs out of an entirely different budget.
No Budget Details for Pretreatment Two of the programs do not have a
pretreatment-specific budget; Therefore, its difficult to identify how much
is being spent on the program overall.
6-19
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Cost Accounting
Col accounting; the process by which the POTW assesses how much particular" discharges
or dischargers cost for their plant to handle, was a weak area in both CA and IN. Widespread cross-
subsidies led to reduced resources for pretreatment and poor price signals to dischargers about the
rhost important areas in which to improve pretreatment or reduce water consumption. Virginia
proved to be similar, although with some interesting twists not found in the other states. For
example despite some costaccounting-problems, one of the programs received more in surcharges
overall than the cost to run the pretreatment program. Virginia POTWs also faced politically-,
induced cross-subsidies, where particular dischargers paid less than their fair share due to political
influence. Virginia also brought out the complex issue of government-subsidized sewage treatment
to large industries fully capable of paying the entire cost of these services on their own.
••' Program A. Program A spread the cost of treatment and administration
throughout its customer base and estimates that its surcharges cover the
incremental costs of serving industrial users and other dischargers of high-
strength wastes, there are no cross-subsidies between residential and
Commercial/industrial customers as occurredin some other programs. There
do appear to be some cross-subsidies among lUs (such as through flat
discharge fees across the entire plant network).7 Fines levied against non-
compliant firms are directed into a special pretreatment budget item that
funds local programs including an industrial awards program, community
education and the POTWs P2 program.
Program B. Although testing is a large part of their budget, they don't
charge back analytics based on the specific cost per test. In addition, they
don't charge smaller dischargers for required tests. Thus, the large lUs
subsidize the .smaller ones to some degree.
i • ' '
The program experienced large cost increases when the cluster rule
came into effect, when they began WET and bioaccumulation testing,
: arid when their new discharge permit increased their monitoring
requirements. - .
Nonetheless, their rates for commercial customers have remained flat
between 1986 and 1994.
? Plant personnel note that they are required by Federal law to have a uniform fee structure;
additional research would be needed to determine whether this precludes the use of differential
charges within a large geographic area, based 6n difference in the cost of providing service.
6-20
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This program, is somewhat unique since the core IUs are allocated fractions
of fixed costs based on loadings (flow and strength), almost as though they
were equity holders'in the plant (in fact, they "own" set proportions of the
treatment capacity., As a result, aggregate charges, are quite sensitive to
loadings; thus, the SIUs want accurate and frequent data on those loadings.
In fact, they want daily numbers for BOD and suspended solids. Thus, each
plant has permanent samplers and uses a flow-through sampler with large
volume samples to try to be sure the reading is representative. This is
expensive: capital costs associated with-this-equipments about$4$00
-------
of their waste, though they have talked about doing so for years. According
to the pretreatment coordinator, a strong local restaurant lobby has long
opposed such surcharges and successfully prevented their implementation.
Despite charging for iab tests, laboratory costs continue to require
about 1/3 of a very small budget, suggesting that more extensive cost
recovery mightbe possible.
In addition, this plant does not charge industries for violations that
force the piant to incur substantial costs to rectify. Given the large
number of.. restaurants,, this particular POTW has had frequent
• problems with oil arid grease discharges. In fact, oil and grease from
these restaurants plugs the pump station on a regular basis, forcing a
sewage maintenance team to flush the pipes as frequently as 2 or 3
times per week. The cost of these, activities is never calculated, and
,iioi Ifibrt has been made to charge the cost back to the responsible
dischargers. ' "'. '
Despite the very low rates at this POTW (only 61 percent as high as
an adjacent community), the POTW has still found it extremely
.difficult to increase charges sufficiently for Ills to cover the costs of
running the pretreatment program.
"VJ
Cross-Subsidies
f|e biggest issue with cross-subsidies in Virginia involved the provision of wastewater
treatment plant infrastructure to industry at below-market rates. At two locations, at least one of the
WWTPs serviced primarily industrial customers, with industrial flow a high percentage of total
flow Althoughi the industries generally contributed to plant construction and sometimes held an
equity interest in me facility, the financing arrangements appear to have subsidized the industries:
« The capital cost of the plants was paid, in part, using EPA grants. While the
: net result was cleaner water, the cost of pollution control was substantially
1 borne by: federal or local taxpayers, r&her than by .the industries causing the
pollution. This subsidy reduced the incentive for these industries to invest
in pollution prevention or waste minimization.
«, Where construction was financed by municipal bonds rather than grants,
", ' industries benefitted from access to lower cost municipal financing.8
s Because interest on municipal bonds is exempt from federal taxation, borrowers are able
to pay a lower interest rate man would otherwise be possible.
6-22
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Where the firms took an equity interest in the plant, it is possible that they.
.receive an ongoing subsidy from the municipality in the form of services
provided by the POTW staff but not charged back entirely to the specific
plant servicing the industry. -
One other area of potential subsidization involves line .extensions to IUs outside of the
service area. Unless the POTW has very good cost accounting systems (which few appear to), there
is a good chance that the cost of these extensions is not accurately charged to the IU or town being
added to the system.
Cost-Accounting for Multi-plant Networks and Interjurisdictiorial Agreements
.Cost accounting for a single waste water treatment plant is complicated; doing so for a multi-
plant network is even more so." A similar situation holds for IJAs; where the plant can't even get
information on what industries are discharging what effluent at what contaminant levels from
surrounding communities, figuring out how much those discharges cost the POTW is nearly
impossible. Since both multi-plant networks and IJAs bring out other general management issues
as well, they are each addressed in separate sections; the cost accounting component is mentioned
there. • ' ' • •
RUNNING A MULTI-PLANT NETWORK
Operating a single sewage treatment plant is difficult enough: local limits must be set, IUs
identified and inspected, and effluent quality protected. Multiple plant networks add an additional
layer of complexity. Since the plants have different capacities and capabilities, controlling influent
parameters becomes more complicated. Multiple outfalls, sometimes in different receiving waters,
make setting local limitsrmore complicated as well. While most of these systems are set up as utility
districts, protecting them in part from multiple political jurisdictions, difficulties over political
boundaries remain. For example, collection systems may be owned by a variety of different
governments, be in differing condition, and be maintained to differing levels.
One of the programs visited managed a number of plants together.
• Local Limits. This plant network had cross-connections between plants,
' allowing influent to be shifted from one plant to another. The benefit of this
approach is that treatment capacity can be balanced system-wide, offering
buffering capacity against influent increases in particular regions. However,
smce one can't be sure ahead of time what outfall particular influent will end
up going to, local limits had to be set system-wide, based on the worst-case
scenario (i.e., most sensitive discharge point drives the entire system).
•'-' . ..' '• '-•''. '• ' . '.:< . 6-23 . • ' ' • • '• •: • '•
-------
The most sensitive treatment process also influences local limits.
One plant has metals-sensitive technology to treat wastes;
pretreatment managers had to be sure their local limits were
protective enough .to prevent plant upsets.
Discharge prices. Given the mix of technologies used in a plant network,
the cost to treat particular discharges can vary widely across the system.
PQTW managers have chosen to have universal charges to dischargers,-
reeardless of what part of the system they are located in. This has the benefit
of simplicity. However, the drawback is that the POTW itself does not know
how much its costs vary across their system. A system of differential charges
could also encourage increased industrialization in the portions of their
network most capable of handling it; or encourage increased investment in
P2 in the parts of their network most constrained.
Cross-Connections Automatic. A series of cross-connections between
plants have been fairly automated so that discharges flow to the point of least
resistance/using a floating valve system. Prior to this system, interceptor
personnel from one plant would divert influent to other plants withou
notifying the plant personnel that it was coming. This caused substantial
problems for the receiving plant, and led to a formal notification system.
INTERJURISDICTIONAL AGREEMENTS
A ^ numbed -of the programs we visited accepted discharges from industries outside oTtheir
mer municipalities was discussed above under the section on the "Most Critical Facto s
n fa Successful Program." This lack of oversight makes proper cost accounting virtually
impossible, and makes cross-subsidies extremely likely.
. Understating the cost of sewer line expansions and may lead to artificially
low charges to industries at the periphery of a sewer network and inhibit the
. adaption of P2 or smaller scale technologies that are alternative ways to treat
vSes In Virginia, one program is expanding its sewer network earlier than ,
originally planned in order to service a large industry in another jurisdiction
(along with the residential customers). The County is contributing
construction funds and the industry is paying sewage treatment charges that
include the debt service on the line extension. The industry will pay
treatment charges, but none of the cost of the line extension. This type ot
arrangement may require additional evaluation to ensure that wastewater
treatment charges to industries are not being subsidized, thereby reducing
their incentive to invest in P2.
6-24
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Another program receives large flows from an electronics company in
another service area. Again, the impact of these flows on plant costs ;and
operations is not incorporated into the prices charged to the IU, since charges
are levied against the adjacent municipality, leaving it up to mat municipality
whether to surcharge the industry correctly.
INFORMATION SYSTEMS
Improved Systems Would be Extremely Valuable
• Information Systems Can Provide a Program History. In a number of the
programs visited, including one in Virginia, a new pretreatment coordinator
arrived and found .very little history on how the program had operated under
prior management. This lack of history greatly reduces the ability of the new
coordinator to dp his job and further improve the program. Information
systems help retain and organize core information on the program and the
* IUs, information that would be available for new staff:
Information Systems in Use at POTWs
• Program A. This program uses an Advanced Revelation Database program
to track pretreatment. Their software gives them automated calculations; for
'.""*• violations, and SNC, and allows them to track monitoring results (such as
comparing self-reported and compliance reporting results). While the
program staff expect to upgrade their systems in the coming years, they
expect this to be a significant challenge because their staff are scientists, not
computer specialists. > - ,
Staff would like to replace most of their paper records with electronic
. . to reduce the space they take up and to make them more easily
accessible. .
~ Staff also want better linking between the lab system and main
. . , database and to have a standard info system across the POTW.
— Despite being a large and complicated facility, the POTW has no
' • digital maps of its sewer infrastructure (not always owned by the
POTW itself), and therefore no GIS. .
— Staff liked the idea of interchangeable program modules that could be
r- shared among pretreatment programs! .
6-25
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Program B This program relies on the Access Database for analytical data
!andHOV information:; They use MS Word for general correspondence. The
program does not have 'a software package' specifically targeted to
pretreatment and the coordinator did not think that the city would be willing
to buy one even if he found one he liked. The coordinator had used Prelim
4.0 (for setting local limits) in the past, and thought that while it was
generally useful, it had bugs.
Program C. The program coordinator mentioned a number of the software
packages that Program C relied on. This included Pretreatment Manager
from ARCCA, which the coordinator said was helpful, but rather old and not
very flexible.9 The program also uses Word Perfect and Quattro for
calculating local limits and other headworks data. Overall, the software does
help them to produce their annual report more quickly.
Program D. This program retains a hard copy of most materials in their files
and relies on spreadsheets and word processing for their data manipulation
and standard correspondence. Despite being a large, complex program, they
have no overall information system -- this is a recognized problem. They
want to improve the pretreatment information systems and improve the links
between pretreatment and other POTW functions. One example where such
sharing would be beneficial is to provide access to routine information such
as sampling results to the plant's operations staff. The pretreatment
coordinator would also like to be able to transmit quarterly and annual reports
electronically: The program has tried a number of pretreatment programs,
including PCME; Operator 1.0, and ARCCA; however, they discarded each
of them because they weren't flexible enough.
„- . i1 " - i j;ii *'.; .:;.'>• i.;1;;.'!.! , ,; ;. _; ;••••• • • . •> , ,• • ',..'•" » ' • •• .<• • ...•.• .>• •• • .flvi'i. ; * ", ..
Use of Geographic Information Systems
None of the programs were making use of GIS at this point in time; nor did they have a
particular vision of how GIS might help them to manage their pretreatment program more
effectively. .
"7
that well.
A number of specific problems with the .ARCCA package included that it was not Windows
- • operated too much like a "black box" making it difficult for them to see their analysis,
" standard forms (that could not be changed) that didn't fit the needs of their program
6-26
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OWNERSHIP PATTERNS
In addition to the reliance on outside laboratories for some types of procedures (described
below), some POTWs outsourced other aspects of their operations as well. Spme pretreatment staff
also shared theu: views on the issue of privatization. --• ..
Outsourcing (Other than Laboratory)
• , Collection systems. While the. POTW owns the major force lines, the cities
and towns own peripheral lines and smaller trunk lines. This pattern seems
- to be rather common for many POTWs.
• Biosolids management. One program outsources biosolids management.
Laboratory Operations "
The Virginia programs had a wide range in how they managed their laboratory operations,
from conducting everything in-house to almost nothing in-house.
• All Tests Conducted In-house. One program owns and operates a state-of-
me art laboratory facility and conducts all tests m-house. This allows them
to have precise control over the quality and speed of testing. The POTW
provides services to other municipaUties and government agencies, but not
.• to any private entities. The facility also does all of their biological tests in-
• • house.
• Only Conventionals Conducted In-house. In contrast, another "of the
. . POTWs visited ships everything out to a contract laboratory other than
conventionals. -
' , - . - " • •' .- ' '"" >
• Program C. A third program contracts out cyanide, oil and grease, and
organics. In addition, it shipped out .metals while upgrading metals testhig
, equipment. This program worked hard to choose a good contract laboratory,
developing criteria for choosing that included a variety of performance
measures before considering price. Despite it's work choosing a lab for itself,
it does not have a list of approved labs for dischargers because it has no
authority to prepare such a list.
, • "Program D. The final program visited does conventional pollutants and
metals in-house. Airborne total hydrocarbons are measured at the lUs using
continuous emissions monitors (CEMS).' Organic priority pollutants and
'•••'' • ' - ''''.- • • • 6-27' : ',".'."•' - ' ' - • .-.' ' ' ' .
-------
some metals, cyanide and whole effluent toxicity are all contracted out. The
plant also contracts "out bioaccumulation testing which is required in their
NPDES permit due to discharge of one of their lUs that bioaccumulates.10
Despite using contract labs, this program has had problems'with every single
one they've used. For example, they have never seen Hg results they
believed. They choose a lab based on QA/QC, an on-site inspection, and
price --though quality much more important. Lab contracts are put out for
competitive bid. -..-..
1 'S li "NVs'Q'1 ''*Li!!,"
"In-Sourcins"
Lab Services. One program provides laboratory service's (at a fee) to other
.municipal entities. .
Service Area Expansion. One program continues.to expand its service
district to an ever wider area. Based on descriptions by program staff, this
expansion seemed rather haphazard, initiated by requests by particular lUs
or surf bunding government entities. There did not seem to be, a strategy
based on what parts of their existing infrastructure were underutilized.
Billing system. Cities in one region may shift to radio metering for
water/wastewater, at which point they would use the POTWs billing system.
VHews on Privatizing PQTWs and Effluent Trading
9 Program A. This program felt that contract-operated POTWs were fine, and
might even work for pretreatment. However, full privatization of
pretrearment would be much more difficult They also thought that effluent
trading on the NPDES side was a good idea, and might even work within a
pretreatment program. However, they did not think it would work with a,
: multiple-plant network where effluent flows could be easily shifted,
• Programs The pretreatment coordinator said that there has been some talk
Of contract management for the plant, but that the operations staff were
holding costs down to stave off the threat. The coordinator said that
privatization of pretreatment would be unacceptable because he didn't see
if since these"tests must be conducted due to one particular IU,pro^ would charge thk
IU the full cost of these tests.
6-28
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how it could then protect the environment. In terms of effluent trading, the
coordinator thought that point-nonpoint source trading might be useful, but
. that the state of VA didn't have enough of an NFS program to support it. He
thought that trading within the pretreatment system would-be unlikely
because all the lUs had already installed their treatment equipment, and
because implementing, it would also require the POTW to shift from
concentration-based to mass-based limits.
.Program C. This plant is already sort of privatized. Although built with
EPA construction grants, lUs bought rights to 85% of .the plant capacity from
the outset. They did not actually take ownership in the plant infrastructure. •
According to the industry, this involvement has had certain risks, because the
plant initially didn't work. ,
>- lUs can sell this capacity.
Industries pay for all O&M on a pro-rated basis. Thus, bear some
risk; if a recession reduces production and discharges from all the
SIUs, charges from the PQTW don't necessary decrease.
We did not have enough information to compare the incentives associated
with this ownership structure,of this POTW to those of a standard contract
managed plant or a fully-privately owned one.
RESIDUALS MANAGEMENT
There was a greater diversity of residuals management techniques used in VA than in the
other states. .
Biosolids ."'._..'
Two of the Virginia programs incinerated most of their biosolids rather than land applying
it. One of them incinerates biosolids because it is cheaper than land application, they think that this
is partly the case because the incinerators have already been built,' and that as they wear out, land
application may become more attractive. The other facility that incinerates their biosolids does so
because of concerns that relatively high levels of organics may remain in the biosolids. .Incineration
vvill successfully burn off any of these residuals. The ash from this second program is composted
with paper mill biosolids and resold.
6-29
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The other two plants rely on land application. One facility has biosolids that meets the Class
B standards; metals concentrations in the biosolids have been flat for a number of years. The other
facility produces biosolids that meets the Class A standards, and contracts.with a third party to
manage their biosolids operations.
Effluent Reuse
Aside from minimal reuse on golf courses, treated effluent is simply discharged. For one
facility, this lack of reuse is due to concerns of the local department of health regarding pathogens
remaining in the effluent that the pretreatment managers think is somewhat unfounded. Since the
region experiences substantial water shortages every summer, the inability to reuse the effluent for
irrigation is, in the minds of program staff, unfortunate. .
SUMMARY OF SUGGESTIONS TO EPA
Information Sharing
• : " *> •
• impact of New Chemicals on Treatment System. Help POTWs evaluate
* how new products (e.g., poly vinyl alcohol from hospital garments) might
affect the operations of the plant.
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• Increased Information Flow from EPA. More discussions and info sharing
between EPA HQ and pretreatment coordinators would be useful. A regional
"news section on PIPES that could also be used to announce seminars in the
area would be useful as well.
• ' increased Training. More regular/basic training.
Don't Forget Delegated Programs
Region Needs to Pay More Attention to Delegated States. A number of
the Virginia facilities felt as though the Region 3 EPA had pretty much
abandoned them, since VA is a delegated state and PA isn't. Although
delegated, they felt as though they also needed support from the Region in
order to be more effective programs. Region 3 should be running regional
seminars.
6-30
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EPA Should Continually Assess Capabilities of Delegated States.
Approval authority for.state water programs is erratic. Some states are
delegated when they do not have programs capable of ensuring water quality.
VA fit into this category.
Regulatory Flexibility
New CIUs increase workload but not necessarily POTW performance,
New CIUs, as well as .the industries requiring oversight under the MP&M
rules, would create a workload challenge in coming years. For example, the
MP&M rule would add over 100 new entities to be regulated in one region,
as compared to only about 13 regulated now. Programs felt it was a waste of
resources to treat small CIUs as SIUs, and that their oversight should be
based on risk.
Required pretreatment standards can sometimes hurt, rather than help,
the POTW. Not all pretreatment programs were designed to meet the same
heeds; the regulatory approach treats them as,such, and therefore causes
problems for some plants. This subset of plants were specially designed to
treat industrial wastes, and certain JEPA requirements regarding organics don't
really apply. For example, methanol discharges are a VOC, and therefore
regulated. However, this is also a food source for the bacteria at the POTW.
If pulled from the influent, POTW would have to pay for other food
sources. /> .
If regulated to such an. extent that discharger had to pretreat for it, the
IU might decide to stop discharging to the POTW outright, with
- significant implications on the economic viability of the plant for all
remaining IUs.u • ,
To address this concern, one plant would like to see a new category:
Publicly Owned Industrial Treatment Work toAddress some of these
. issues. While §307(b) of the CWA gives POTWs some flexibility to
issue lUs a "credit" reflecting the POTWs ability to treat a pollutant,
the plant stated that the process to do so is costly and administratively
cumbersome. In addition, it does not allow an adjustment to reflect
the full ability of the POTW to treat particular wastes.
11 This is especially an issue related to the technology-based standards for the pulp and paper
and the OCPSF categories. The plant in question would become uneconomical if these industries
pulled out, even though their plant is already built and capable of treating the organic wastes for
, these industries (they have few metals). - ' . '
, ' ; • -.' • . •• ' '6-31 ' " ' . . ' • '...•'•"'•• •"'.
-------
A related regulatory issue involves where "compliance" is measured:
' , • atthe discharge point of the SIU, or at the point of discharge from the
POitW. this plant wants theBlatter, but says that the former applies,
ignoring the ability of the plant to treat the discharges.12
Latitude for permit modifications unclear. One program felt that it was
riot always clear how to differentiate a substantial versus a non-substantial
modification. Minor modifications do not go through a formal approval
process, as long as the Approval Authority does not object they can be
implemented immediately. Additional guidance might be in order.
Simpler Annual Report. One POTW felt that Annual Reports should be a
summary "of program changes for the year, rather than a compilation of
inspection reports and compliance status. This coordinator felt that EPA
should be concerned with whether the POTW itself was meeting its permit
rather than the activities of each IU. - ' -
Faster response times on audits and reviews
• One program implements new policies before getting official EPA approval.
Their ERP and sewer use ordinance has taken three years thus far. The
program manager got a call a few days before our visit from EPA asking for
new copies of these materials because EPA had lost theirs.
SUGGESTIONS FOR THE CSI PROJECT
• Increased EPA Resources to Education and Field Inspections. One
program wanted EPA to refocus resources to more targeted inspections,
industry education, more field inspections. CSI can help encourage this shift.
• Less micro management by EPA. Focus on POTW as Control Authority
and states and EPA as Approval Authority. The implication of this
suggestion.is less micro management ofPOTW operations. This can only
work if the POTW is able to demonstrate to EPA, the states, and citizens, that
its performance is good..
12 Program staff said that fugitive emissions (that would be lost between the two different
measuring points) were less than one percent. , -
;: ' ' ";;;:"'. ";': ' ••• !•:• •. •"• ':•'•"•• 6-32 ' ' " ' " '; ":' .' ' "
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Focus on environmental results; give programs increased flexibility to
achieve. Increased flexibility in the pretreatment program would be very
useful. One program felt.that the current program was too prescriptive and
riot enough oriented on environmental results. This coordinator favors
outcome-based standards rather than technology-based standards. The key
outcome-oriented measures in his mind are: meeting all worker health and
safety standards; quality effluent; quality biosolids; quality air emissions;
CSO and SSO quality and. abatement; recycling and reuse of water, air,
biosolids, and biosolids byproducts. . ,
Identify Better Results-Based Measures of Performance. CSI can help
develop better ways to describe the impact of the pretreatment program
through performance measures. These measures must be measurable and
understandable, What is the POTW doing? How well? It is a common
problem across programs that politicians disregard the importance of
pretreatment. In addition, the measures would help support a shift to
increased flexibility for programs to decide/or themselves how best to
expend their resources. ,
• ' ' '"., . •-." v. _ ' i . .
Paperwork and certain other violations are not important. De-emphasize
enforcement of violations that have no impact on environmental quality such
as paperwork (excluding falsification or non-reporting) and instantaneous pH
(which this program manager characterized as "meaningless").
6-33
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Attachment?:
SUMMARY LIST OF ALL POTENTIAL PILOT PROJECTS SUGGESTED DURING SITE VISITS
Potential Project
1 • ~ " -S
1. Upgrades to PIPES
a. Put old EPA guidance manuals on the system.
b. Allow document viewing before downloading.
c. Provide industry-specific, user-friendly information
on P2 tailored for pretreatment staff.
c.(l) Prepare support materials to show the
economic benefits ofP2/Collect Performance data on
equipment and technologies.
d. Expand access to PIPES/ upgrade to full World
Wide Web capacity.
d. (1) Restart National Pretreatmeni Bulletin
e. "Plain English " updates and summaries of-
regulations of concern.
f. Compilation of SNC/NOVs for the nation. :
g. PIPES regional calendar, to. which states and
regions could add activities.-
h. Permit "helper" for holders of out-of-date NPDES
perrnits. •
2. Cost Accounting and Budgeting: Sending the
Right Price Signals to Polluters
-a. Escondido cost accounting .
•». . ' ' • • •• ' ' •- •
b. Model budgeting system
3. Model Inter- Jurisdiction^ Agreement (IJA)
'..-_, . . Purpose
Meet expressed needs of POTW pretreatmeht staff.
Old guidance still useful but difficult to obtain for programs with high
staff turnover.
Avoids wastingtime'downioadmg documents erroneously.
Helps both PQTWs and Ills; reduces the current duplication of effort.
Give inspectors and programs packaged information to encourage small
businesses to cdmmit to P2; help them overcome resistance to new
investment. .. '
Increased dissemination of information to interested parties.
Provides an off-line mechanism to keep pre-treatment staff up-to-date.
Supplements or duplicates 6n-lke information? .
Small programs have a difficult time tracking and understanding
regulations relevant to their operations.
Small newspaper adds attract little attention; compilation would give
small programs in politically-difficult regions the leverage to obtain
behavior change from SIUs. .
Seminars/workshops of interest are often not publicized sufficiently for .
nearby POTWs to benefit
POTWs with long-expired NPDES permits do not know what areas they
will need to upgrade when their permit is finally rewritten; therefore,
they have a difficult time making the proper incremental improvements
to their programs. -
Both dischargers and the POTWs make decisions, in part, based on
costs. If the cost information they use in these decisions is wrong, they
may underinvest in pretreatment equipment, or in the pretreatment
program overall. ,
Escondido had numerous cost accounting issues that affected
pretreatment economics. It would provide a good case study to illustrate .
how "getting the prices right" would change pretreatment behavior.
Some programs provided pretreatment staff with no information on
available resource. Others did not budget capital purchases properly.
This project would illustrate how successful budgeting systems would
help managers to better protect the environment.
Many POTWs accept industrial discharge from Ills in surrounding areas,
but have no direct enforcement or monitoring controls. This project
would create a model IJA that, if implemented, would ensure
pretreatment programs had adequate control over their dischargers.
7-1
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4. Staff Training
a.
Training Videos:
ft) Program basics, including how a strong
pretreatment program helps business
(2) Sampling
(3) Doing an inspection
(4) Conducting a show-cause hearing .
(5) Classifying lUs •
(6) Computer systems
(7) Industry-specific guidance and training
videos.
b. "Guidance" to the guidance: "ramp-up" course for
a new pretreatment coordinator
Address a variety of the training needs, communicated by pretreatment
staff. ' ' ^^_^__^___
To bring .targeted expertise to remote programs without travel budgets;
to help lUs improve their pretreatment systems by giving them insights I
into what a pretreatment inspector is looking for during a site visit.
b. (I) Develop strategies to assist small pretreatment
programs.
b. (2) New employee pretreatment orientation
manual.
c.
Choosing a contract laboratory
c. (I) Laboratory certification program
1 ^ •
To provide a simple "roadmap" for a new pretreatment coordinator aboj
what they are responsible for, where they can get a quick overview of
each area of responsibility, and resources they can use for upgrading
their knowledge base. • ; ;
Targets many of the programs most in need of help. A number of
possible strategies have already been listed, including the guidance to I
guidance, other training initiatives, and increased regional meetings.
Similar to main guidance, but targeted to the employee rather than the
program manager. (Unclear how different this would be from the —'*
guidance).
To help pretreatment staff understand how to evaluate the contract labsl
on which much of their program effectiveness relies. This was identifia
as an area-of concern by a number of the programs we visited.
^-™-^!^™T^"™^^^^^^^^^^^
d. Initiate regional pretreatment meetings, supported
(though not funded) by EPA regions
d. (I) Develop strategy to leverage state pretreatment
organizations (e.g., VAMWA) to provide training and
support. : .
d. (2) Initiate exchange programs between POTWs
Develop national certification for laboratories to improve the quality
reliability of POTW and IU sampling data. '
To provide additional training opportunities that many programs felt'
lacking. ,.
Leverage non:EPA resources.
e. Prepare new guidance materials:
(I) Sludge regulations.
(2) Short, concise guide to proper sampling
techniques.
(3) Update local limits guidance.
5. Information Systems Transfer
a. Data sharing between related functions
b. Upgrade PCME software
Would allow mentoring across POTWs, with managers from the s
programs spending some time at the best ones.
Address informational gaps people felt currently exist.
Programs are duplicating a great deal of effort to develop pretreatmen
information systems. This project would develop ways to reduce this
duplication and facilitate exchange/sale of existing systems among
POTWs. ' •• '
Use'GIS approach to demonstrate environmental and financial benefi
of data sharing between WWTP, storm water manager, CSO manager,J
industrial waste manager, and collection systems manager.
Modify existing software (almost universally disliked by POTWs) to
meet the needs of more POTWs and improve the compatibility with
other systems. _____
7-2
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c. Develop IU data management system ...
d. Pilot and implement electronic reporting
6. Inspection streamlining ,
7. Evaluating impact of new discharges on POTW
8. Place-based regulation of water quality.
9. Regulatory modifications
a. De minimis exemptions for categorical users.
a. (I) Increased flexibility for permit modifications
a (2) Pilot and implement risk-based performance
measures/environmental indicators
b.- Standardize reporting for the many state and
federal requirements.
c. Certify IU pretreatment operators and/or
pretreatnient inspectors.
d. Change definition ofSNC.
e. Reduce or eliminate required testing for pollutants
not in use at an IU. . . .
10. Other potential projects
a. Develop glossy PR package for the pretreatment
program.
•*, , • , :
Would help IL's manage, pretreatment and other data reporting needs and
improve report quality.
Reduce paperwork and potentially reduce costs of reporting.
Ills face inspections from numerous federal and state environmental
inspectors; each- visit requires them to take time away from operating
their businesses. This project would test out how to combine and
consolidate inspection visits in a particular geographic region.
New materials are constantly entering the marketplace; residuals often
then enter the POTW system, this, project would develop an organized
way of testing these materials to be .sure they didn't inhibit POTW
functioning. •
POTWs regulate only indirect dischargers, though direct dischargers can
have a substantial impact on the quality of receiving waters into which
the POTW discharges. This project would compare the quality of
receiving waters between regions that have locally-based regulatory
control over the entire water-body with those that don't (i.e., most
POTWs). .
While not pilot projects, per se, there were a number of suggested areas
for improvement from the programs we visited.
Small CIUs take up substantial staff time even when they don't .
contribute very much loadings to the POTW. Exempting the small CIUs
from regulation will free staff time for more important dischargers.
With some safeguards, allow good programs to modify permits and local
limits with approval. ..-'.'
As with the projects listed above, this would allow POTWs greater
discretion on resource utilization, to focus on high risk areas.
Would reduce the redundancy of collected information, reducing the
burden and costs on pretreatment program staff.
Would .professionalize these personnel, reducing discharge violations
due to poor staff training.
Some programs felt the current definition of SNC doesn't highlight the
proper "bad actors."
Reduce testing costs/burden on HJs for materials they don't even use (but
could, theoretically, use hi their processes).
Some programs felt that the pretreatment program didn't sell itself well
to compete for funds and management attention. This package would
help increase the program's visibility. ,
7-3
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