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Step 1 is the planning step. During this phase the facility planning
process begins with a plan of study. This plan outlines the work to be done
in preparing a facility plan. Next, a preapplication conference explains the
construction grants program and its requirements. The application is then
submitted for approval. After the grant is awarded, a facility plan is
developed.
Following approval of Step 1, the applicant proceeds to Step 2, the
design phase. (Although Step 1 has been approved/ this does not obligate
EPA to fund Step 2 or Step 3.) There are numerous program requirements
which must be met before Step 2 is approved.
Step 3 is the construction phase. During construction, several
inspections are made to ensure proper construction of plants in accordance
with approved plans and specifications and safety and storage of materials.
During Step 3, the final plan of operation, O&M manual, user charge,
industrial cost recovery, sewer use ordinances, and start-up services must be
submitted and approved. A final inspection is required prior to final
payment. After this payment is made, a final audit is conducted. When all
of the above is completed and in compliance, Step 3 is concluded.
Followup is required after Step 3. States are required to inspect treat-
ment works periodically for evidence of compliance with permit requirements
and to evaluate procedures.
It should be noted that Step 2 and Step 3 may be combined into one
grant application. However, the grantee is still responsible for meeting all
O&M requirements for Step 2 and Step 3 grants.
In conclusion, the construction grants program addresses operation and
maintenance considerations. Inadequate consideration of operation and
maintenance has occurred in the past. Becoming aware of O&M considerations
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is the first step in correcting this problem. It is important to implement
these considerations throughout Steps 1, 2, and 3 and in the preapplication,
predesign, and preconstruction conferences. Training is required to develop
an understanding of these considerations.
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O&M
CONSIDERATIONS
STEP1
CONSTRUCTION GRANTS PROCESS
UNIT
2
2-1
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UNIT TWO
OBJECTIVES
Following the Unit Two presentation, the participant will be able to:
1. Identify and discuss Step 1 of the Construction Grants Process.
2. Explain the importance of operation and maintenance requirements in
Step 1 of the Construction Grants Process.
3. Determine and discuss where operation and maintenance must be stressed
in three specific phases prior to Step 1 of the Construction Grants
Process:
a. Preapplication Conference
b. Plan of Study
c. Facility Plan
4. Recognize and discuss possible problems if operation and maintenance is
not considered in Step 1 of the Construction Grants Process and explain
how these problems can be avoided.
5. Utilize the Preapplication O&M Consideration Checklist, Plan of Study
Review Operation Checklist, and the Facility Plan Review Operation
Checklist when conducting an operation review.
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UNIT TWO
OUTLINE
I. OVERVIEW OF THE STEP 1 PROCESS 2-4
A. State Planning Process
B. State Priority System
C. Preapplication Conference
D. Clearinghouse Review (A-95)
E. Plan of Study
F. EPA Application Form 5700-32
G. State Priority Certification
H. Selection of Professional Engineer
I. Effluent Limitations
J. Alternatives
K. Infiltration/Inflow Analysis
L. Sewer System Evaluation Survey
M. Public Input
N. Selected Alternative
O. Review, Certification, and Approval of Plans
II. PHASES WHERE O&M MUST BE STRESSED 2-11
A. Preapplication Conference
B. Plan of Study
C. Facility Plan
III. PROBLEMS THAT MAY DEVELOP IF O&M IS NOT CONSIDERED IN STEP I 2-26
IV. PREAPPLICATIOrj CONFERENCE O&M CONSIDERATIONS FOR DISCUSSION 2-31
V. PLAN OF STUDY REVIEW OPERATION CHECKLIST 2-33
VI. FACILITY PLAN REVIEW OPERATION CHECKLIST 2-34
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OVERVIEW OF THE STEP 1 PROCESS
State Planning Process
Public Law 92-500 requires each state to establish and maintain a
continuing planning process. This planning process must be reviewed and
approved periodically by the EPA. It must be consistent with the law and
must include the following:
1. Section 303(e) plans (more commonly known as river basin plans or
waste load allocation plans)
2. Areawide waste treatment management plans (more commonly known
as 208 plans)
3. The state priority list
River basin plans 303(e) establish the water
quality standards for each segment or body of water
within the river basin. Segments are classified as
"effluent limited" or "water quality limited." On
"effluent limited" stream segments, all sewage
treatment works shall provide a minimum of secondary
treatment. On "water quality limited" stream segments, all treatment works
must provide a higher degree of treatment in order to meet water quality
standards.
This classification is the first indication of the scope of operation and
maintenance to be encountered when the plant is put into operation. The
stream segment classification should alert state, federal, and local groups to
the complexity of O&M requirements, costs, and importance in the planning,
designing, constructing, and operating of future plants in that particular
stream segment.
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Areawide waste treatment management plans (208) are usually prepared
for urban-industrial areas. These areas normally have problems with water
quality control due to a concentration of people and industries.
State Priority System
The states must prepare a municipal discharge inventory which rates or
ranks all of the significant discharges within the state. This inventory must
be considered with the stream segment 303(e) priority ranking. The state
then develops a system of ranking projects for funding. This system of
ranking gives consideration to:
1. The severity of pollution problems
2. The existing population affected
3. The need for preserving high quality water
4. National priorities
5. Any additional factors considered significant by the state
This project priority list represents projects which are anticipated to be
funded with the state's allocation of construction grant monies.
A public hearing on the priority list must be
• — - i ,,.
/{M
held. At this hearing, communities concerned with «flb -VA /ti/Jlr
the funding of a project may make their interest
known. Large numbers of prospective grantees are
present at this hearing. It offers an opportunity for
state construction grant personnel to emphasize that,
while the federal government is providing 75 percent of the funding to build
the facility, monies for proper operation and maintenance of the facility must
be budgeted by the grantee.
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Preapplication Conference
An applicant is usually unfamiliar with the requirements and/or
limitations of the construction grants program. Federal regulations encourage
preapplication conferences with the applicant and with state and regional EPA
representatives. This conference sets the stage for a good working
relationship. It involves applicants who are on the state priority list. While
this step is optional, its importance cannot be overemphasized.
This conference offers another opportunity for state and regional
officials to stress that good planning, design, and construction are of little
value if O&M considerations are neglected.
Clearinghouse Review (A-95)
This system is established to provide for early contact between
applicants and all interested governmental agencies. It is important that the
project has the approval of all parties concerned. Copies of the comments of
all interested parties must be included in the application package.
Plan of Study
A plan of study outlines the work involved in the preparation of a
facility plan. This is the first element of the grant request that must be
submitted by the applicant. The plan of study should describe briefly the
scope, schedule, and costs of the proposed facility plan.
EPA Application Form 5700-32
EPA Form 5700-32 is the formal application document.
State Priority Certification
This document certifies that the applicant is on the state priority list.
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Selection of a Professional Engineer
When selecting an engineer, the grantee should look for the following:
1. Specialized experience and technical competence of the
engineering firm and its staff
2. Past record of performance in fulfilling contracts
3. The firm's capacity to perform the work within time limitations
(the firm's current workload must be considered)
4. The firm's familiarity with types of problems applicable to the
project
5. No indication of conflict of interest
Effluent Limitations
The degree of treatment which must be provided by a particular
treatment plant is dictated by the effluent limitations. Public Law 92-500
established the National Pollution Discharge Elimination System (NPDES) which
sets effluent limitations. The effluent limitations include biochemical oxygen
demand (BOD^), total suspended solids, and any other effluents limitations
%J
that may be discharged into a stream. The effluent limitations vary according
to the nature of the receiving stream. The effluent limitations are of
considerable importance because they determine the type of treatment works
needed and the operational efficiency required.
Alternatives
A facility plan must investigate and evaluate alternative solutions to the
water pollution problem. The following questions must be resolved:
1. Can the existing plant be improved by better operation,
maintenance, laboratory control, or management to the point where
construction may be minimized or eliminated?
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2. If number 1 is not practical:
a. Should the existing plant be modified?
b. Should a new plant be built?
c. If so, where should it be built?
d. What type of process should be used? ¥///tt/ './','>>''. -\
', ''ill. ' . , •
3. Which of the following waste treatment management techniques seems
most appropriate?
a. Biological treatment and discharge into the receiving stream
b. Physical-chemical treatment and discharge into the receiving
stream
c. Treatment and reuse
d. Land application
e. No action
4. Factors to be considered in choosing treatment management
techniques include:
a. Engineering feasibility
b. Environmental impact
c. Cost
d. Ability of applicant to implement the technique
Infiltration/Inflow Analysis
The facility plan must contain an infiltration/inflow (I/I) study. (Infil-
tration is ground water which leaks into the sewers; inflow is storm water
which enters the sewers.) During start-up the engineer should check the I/I
study to determine if excessive I/I was eliminated.
An infiltration/inflow (I/I) analysis should indicate the:
1. Cost of transporting I/I
2. Cost of treating I /I
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3. Cost of removing all or part of I/I
4. Amount of I/I to be removed and amount to be left
5. Need for a sewer system evaluation survey
Sewer System Evaluation Survey
This survey is conducted only if the I/I analysis indicates that excess
I/I exists. The evaluation survey consists of some or all of the following:
1. A physical survey of the system
2. Smoke bomb or air pressure testing
3. Selected sewer system cleaning
4. Visual (TV or photographic) inspection of selected sewer sections
5. Preparation of a report
The evaluation survey will identify specific sections of the sewer system
which must be repaired by:
1. Grouting
2. Sealing
3. Lining
4. Replacing
Public Input
The public should participate from the beginning in facility planning.
This allows interests and potential conflicts to be identified early and
considered as the planning proceeds. Public hearings should:
1. Define issues
2. Analyze information
3. Explain costs
4. Discuss alternatives
5. Allow all interests to be heard
6. Emphasize O&M costs
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The reviewer should review transcripts of the hearings to determine the
extent to which O&M costs were discussed.
Selected Alternative
After all investigations and alternatives are evaluated as part of a
facility plan, one alternative is selected and described in greater detail. The
selected plan describes the project for which Step 2 and Step 3 construction
grants may be requested by the applicant.
Review, Certification, and Approval of Plans
The three levels of review of a facility plan are:
1. Review by clearinghouse (A-95)
2. Review by state
3. Review by EPA
EPA will review for approval only those facility plans which have
received clearinghouse and state approval. (These reviews may be
simultaneous.) The EPA Regional Administrator has the authority to approve
any facility plans submitted by a state within his/her region. The applicant
is then ready to complete the application for a Step 2 grant.
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PHASES WHERE O&M MUST BE STRESSED
Preapplication Conference
A preapplication conference should be held with all applicants.
Representatives of the state, EPA, and the applicant should be included in
these meetings. This conference is not required; however, it is strongly
recommended.
The goal of this conference is to produce a well-coordinated program
that avoids pitfalls and delays. The entire O&W1 construction grants process
should be addressed with emphasis placed on Step 1 program requirements.
Topics to be covered include such areas as administrative and technical
requirements. Additional meetings should be conducted prior to Step 2 and
Step 3.
Public Law 84-660, section (8)(b), PL 92-500, section 204(a), and the
Code of Federal Regulations, 40 CFR 35.935-12 (Operation and Maintenance),
clearly state the requirements for proper operation and maintenance of
federally funded facilities. Improper operation and maintenance can void
federal expenditures for pollution abatement. This must be explained to the
applicant. A review and discussion of the applicant's past record on
previously funded projects should be covered. Approval of Step 1 awards
should be tied in with proper operation and maintenance of existing facilities.
The O&M requirements of 40 CFR 35.925-10, Operation and Maintenance
Program, 40 CFR 35.935-1 (b), Grantee Responsibilities, and 40 CFR
35.935-12, Operation and Maintenance, should be covered. In 40 CFR
35.925-10 the applicant has to show that provisions have been made to assure
proper operation and maintenance of the treatment works and sewer system
and to comply with 40 CFR 35.935-12. Under 40 CFR 35.935-1 the grantee
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agrees to complete the treatment works according to approved plans and
specifications and to maintain and operate the treatment works for its design
life. Failure to do so may cause recovery of federal funds (according to
40 CFR 35.965, Enforcement). The Code of Federal Regulations,
40 CFR 35.935-12, is one of the most important regulations concerning O&M
considerations in the grants program. The CFR lists documents that are
required and describes the grantee's and state's responsibilities in regard to
operation and maintenance. Also included in the CFR is a payment schedule
requirement.
A documentation of the influent flow and load characteristics is needed.
The applicant needs to show what data was used to determine flow and load.
The reviewer needs to determine if this data is realistic.
If the applicant has an existing plant, a cost analysis evaluation of
optimum operation and maintenance of the facility should be included in the
facility plans. If upgrading of operation and maintenance is cost-effective,
then new or supplemental construction is not necessary.
The applicant should be informed that a plan of operation is required
(40 CFR 35.935-12). A preliminary plan must be submitted with plans and
specifications in the Step 2 application [40 CFR 35.920-3 (c)(3), Contents of
Application]. The final plan of operation must be submitted and approved by
the time 50 percent of the Step 3 grant payment is made. The applicant must
know and understand what a plan of operation is. Program Requirements
Memorandum (PRM) 77-3 should be used to explain the plan of operation.
From this PRM, the applicant will gain an understanding of a plan of
operation and its funding eligibility under the grants program.
The Code of Federal Regulations (40 CFR 35.935-12, Operation and
Maintenance) requires the preparation of an operation and maintenance
manual. This is a requirement of the Step 3 grant process. The engineer
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should be encouraged to begin development of this manual when drawing the
plans and specifications. Sometimes the engineer who starts a project is not
the one who finishes it. The practice of first preparing a rough draft O&M
manual will aid new personnel in producing a usable O&M manual. It must be
stressed to the applicant that a preliminary draft of the manual is required
by the time 50 percent of the Step 3 grant payment is made; the final manual
is required by the time 90 percent of the Step 3 grant payment is made.
Program Requirements Memorandum 77-2 (Grant Eligibility of Start-up
Services) should be explained during the preapplication conference. This
PRM identifies certain services performed during the start-up period of a
treatment works that are eligible for grant funding. These services should
ensure that the operational objectives of the treatment works will be achieved
quickly and effectively. Emphasis should be placed on early planning for
start-up services. Early planning will make the applicant aware of operation
and maintenance concerns throughout the entire grant process.
The applicant must be informed of the obligations which follow
construction. The plant must be operated and maintained to meet its NPDES
permit. The funding for operation and maintenance of the treatment works is
the grantee's responsibility. This money will come from the user charge
system and the industrial cost recovery system. These should generate
enough revenue to effectively and efficiently operate the wastewater treatment
facility.
The reviewer should become familiar with and use the checklist titled
"Preapplication Conference, O&IV1 Considerations For Discussion." Use of this
checklist will help to ensure that the O&M requirements of the construction
grants process are explained to the applicant.
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Plan of Study
The plan of study is the first element in a request for grant assistance.
It is not a facility plan nor is it part of a facility plan.
The plan of study: (1) lists the required tasks
to be accomplished in preparing the facility plan,
(2) assures that the applicant will complete the
facility plan in accordance with all applicable laws and
regulations, and (3) lays the groundwork for the
facility plan.
The reviewer should utilize the Plan of Study Review Operation Checklist
when reviewing the plan of study. It can be a useful reviewing tool which
helps the reviewer ensure that O&M concerns are considered in the plan of
study.
The plan of study should be reviewed very carefully. It must meet all
the statutory requirements of 40 CFR 35.920-3 (a), Contents of Application.
It must contain the following information:
1. A description of the proposed planning area (including maps)
2. An identification of the entity or entities that will conduct the
planning
3. A statement of the nature and scope of the proposed Step 1 project
and public participation program, including a schedule for the
completion of specific tasks
4. An itemized description of estimated costs for planning of the
project
5. Any significant public comments
The planning area (number 1 above) must be examined closely. This
section of the plan of study should provide a brief description of the plan-
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ning area, its size, population, governmental entities, and type. This
information will have an effect on O&M considerations. The planning area will
determine the size and type of treatment and sludge disposal. Also, the
water table, soil, lakes, and rivers will affect the type of treatment needed
as well as the O&M of the facility.
The entity or entities that will conduct the planning also affect O&M
requirements. The reviewer should review O&M performance at existing
facilities. Past performance often indicates future performance. Other O&M
concerns include the financial responsibility of the entity(ies) and its ability
to attract trained personnel.
Since the facility plan is dependent upon the plan of study, attention
must be focused on those items necessary for its development. The reviewing
agency should pay close attention to the nature and scope of the proposed
Step 1 project. A schedule for the completion of specified tasks and an
itemized cost estimate of the project should be included in the plan of study.
In addition, it must demonstrate that all statutory requirements of the entire
construction grants process are understood by the applicant and that these
requirements will be complied with. From the information provided, the
reviewing personnel need to ensure that all operation and maintenance
program requirements for a facilities plan and Step 1 grant application are
included. Each task listed should be evaluated in terms of O&M program
requirements. Each task in the plan of study should indicate that the
applicant knows and understands the importance of operation and
maintenance, whether it is a program requirement or not. The reviewing
agency should ensure the applicant's consideration of:
1. Proper and efficient O&M of the existing plant
2. O&M costs and their inclusion in the development and evaluation of
alternatives
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3. Public notification of O&M costs
4. O&M costs as reflected in preliminary design cost estimates
5. The development of a preliminary O&M manual
6. O&M funding with user charge system and industrial cost recovery
7. The development of start-up services
8. The development of a plan of operation
NOTE: The applicant would also be required to show that Sec. 204(a)(4) of
PL 92-500 as amended will be complied with. (This section requires that the
grantee will properly operate and maintain the federally funded wastewater
treatment facility.)
The reviewing agency should review the transcript of all public hearings
for any public comments that may affect O&M or its funding. If the public is
against the proposed project for any reason, proper and efficient operation
and maintenance of the wastewater treatment works is jeopardized.
The plan of study will also contain data on infiltration and inflow. If I/I
is not a problem, the applicant must provide written certification by the state
that excessive infiltration and inflow does not exist. If it is a problem, then
the applicant must indicate that detailed sewer evaluation is needed.
After reviewing the plan of study, the agency may approve or
disapprove it. If approved, and a grant offer is made and accepted, the
applicant may begin to develop the facility plan.
Facility Plan
The facility plan is begun after the plan of study has been approved
and a grant offer has been made and accepted. However, state review
program responsibility does not end with a grant offer. As the plan
develops, it should be reviewed on an ongoing basis. This will assure that
all requirements are being met and will allow needed changes to be made.
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The complexity and scope of the project dictates the details of the
facility plan. The reviewer is allowed to exercise flexibility in advising
grantees on facility plan requirements [40 CFR 35.917-4 (b), Planning Scope
and Detail].
The regulatory requirements for a facility plan have been set (40 CFR
35.917-1, Contents of a Facility Plan). Briefly, the plan must contain:
1. A description of the treatment works including preliminary
engineering data, cost estimates, and completion schedules for
design and construction
2. A description of the complete waste treatment system
3. Documentation of infiltration and inflow
4. An analysis of cost-effectiveness including:
a. A statement relating capacity to needs and land reserve
b. Measures for flow and waste reduction
c. A description of optimum performance of the existing facility
d. A statement of ability to meet effluent limitations
e. A description of application of the best, most practicable waste
treatment technology
f. Method of disposal of effluent and sludge
g. Impact on the environment
5. A statement of effluent limitations or NPDES permit
6. Clearinghouse comments
7. A summary of the public hearing
8. A financial statement which verifies that the grantee has the
resources to construct, operate, and maintain the treatment works
9. Proof of compliance with the Civil Rights Act of 1964
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In conducting the review, the reviewer should use the Facility Plan
Review Operation Checklist. This checklist was developed as an aid to the
reviewer. Its proper use will help ensure the consideration of O&M concerns
in the construction grants process during the development of the facility
plan.
These requirements overlap each other in many instances and may not be
understood by the applicants or their consultant. With this in mind, EPA
published Construction Grants Program Requirements: Guidance for Pre-
paring a Facility Plan, Revised May 1975, (MCD-46), (EPA-430/9-76-015),
which includes a suggested format. The intent of this publication was to
simplify the procedure for the applicant. The review procedures and
included checklist discussed in this handbook will be based upon the
suggested format.
The reviewer must pay close attention to the effluent limitations stated in
the facility plan. These limitations determine the type of treatment needed.
These limitations are an indication of the type of plant operation and
maintenance required to achieve the allowed effluent. The establishment of
the effluent limitations is a state responsibility. The reviewer needs to
ensure that proper data is used by comparing the applicant's data with
limitations set by the state.
When reviewing the current situation, the reviewer must determine that
an inventory of wastewater flows and the treatment system has been
submitted.
The inventory should include:
1. Location of all treatment facilities
2. Location of all sewer systems
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3. A description of all facilities (including design capacity and existing
flow and load)
4. A list of industrial users
5. An analysis of peak, low, dry, and wet weather flows
6. A diagram of bypasses and overflows
7. A program to reduce inflow/infiltration
8. A program of user conservation
The purpose of this inventory (along with the population projection) is to
furnish data from which future flows will be determined. It may also indicate
the severity of the pollution problem.
Another problem that will affect the O&M of a treatment works is
infiltration and inflow. A sewer system evaluation is part of a facility plan.
This evaluation consists of an infiltration and inflow that can be economically
eliminated. This reduction in I/I may eliminate the need for any additional
treatment works by altering conditions at the existing treatment facility.
Performance of the existing treatment facility needs to be evaluated by
the applicant. The major components of the existing system are evaluated for
possible use in the new project. This section will explain the problems that
are affecting plant performance and will present methods for correcting these
problems. If it is economical and environmentally sound, the existing system
should be utilized. In the evaluation review, the reviewer must consider:
1. Adequacy of treatment plant design for type and amount of flow
2. Adequacy of operation and maintenance
3. Effects of I/I
4. Effects of industrial users
This evaluation must be carefully weighed before it is accepted or rejected by
the reviewer.
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The applicant must develop a forecast of future
flows and loads. This forecast is based upon future
land use plans or development patterns, and economic
and population projections. The reviewer needs to
ensure that reliable data and methodologies were used
in projecting future flows and loads.
This projection, along with the existing flow and load, will determine
what degree of treatment is needed to achieve the effluent limitation. The
more complex the treatment, the more complex the O&M procedures.
From the above data, the applicants or their consultants will evaluate
possible alternative solutions to correct the pollution problem. The first
alternative is use of the existing facility. As noted earlier, many treatment
works are not being operated or maintained properly. Optimum operation of
the existing facility must be considered. In responding to this, the reviewer
will determine whether or not the applicants or their consultants gave
adequate consideration to this alternative. An intensive review by the
reviewer may be required. The reviewer must keep in mind that the
consultant may be looking for a job or the applicant may have little or no
knowledge of the wastewater treatment system and its function.
The reviewer should obtain data on design, actual flow, plant and/or
unit efficiency, treatment deficiency, age, useful life of planr, type of O&M
program, existing O&M inspection reports, pretreatment requirements, I/I
reduction, modifications needed, and costs. Improved O&M of the existing
plant may reduce or eliminate the need for new facilities.
The applicant must also investigate other wastewater treatment facility
alternatives. In so doing, the applicant must consider the following options:
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1. No action
2. Flow and waste reduction
3. Use of existing sewers and interceptors
4. Sludge disposal
5. Best practicable waste treatment technology (BPWTT)
6. Use of industrial services
Investigation of the above will help the applicant eliminate many alternatives.
This number can be reduced by further using sound engineering, environ-
mental, and ecomonic principles. After selecting the most feasible
alternatives, an evaluation of each (money, environment, implementation) is
completed in order to select the most cost-effective and environmentally sound
project.
A monetary cost analysis must be conducted during the evaluation of the
most feasible alternatives. It should include capital and operation and
maintenance costs.
NOTE: Monetary cost should be shown in
total in terms of its full
impact on the average citizen
and industry being served
monthly and annually. Included
should be the capital cost of
the grantee (local share),
interest on borrowed capital,
sinking fund costs, O&M cost,
connection charges, etc.
Close attention must be paid to O&M costs and anticipated revenues. These
costs must be realistic to the type of process and treatment work size. A
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user charge system must be developed from the projected O&M costs. This
user charge must provide enough revenue for the proper and efficient
operation and maintenance of the wastewater treatment facility.
Other important O&M considerations in the evaluation of alternatives are
flexibility and reliability. The applicant needs to consider: (1) future plant
expansion and land requirements, (2) easements and rights-of-way for the
sewer, (3) the treatment process, and (4) equipment and personnel. The
applicant's consideration of these must be ensured by the reviewing agency.
After careful evaluation of all feasible alternatives, the applicant holds a
public hearing. Using input from this hearing, the most cost-effective and
environmentally sound alternative is selected.
The preliminary design of the selected treatment works should be
reviewed carefully. The type of process needs to be reviewed and the
complexity and cost of operation and maintenance determined. Many cities are
not properly operating or maintaining their existing wastewater treatment
facilities because it would bankrupt them. Others are unable to obtain
needed personnel to operate a complex treatment process. The treatment
works design and process should be based in part on the entity's or entities'
ability to fund operation and maintenance and to attract qualified personnel.
In reviewing the selected plan, the reviewer needs to ask the following
question: "If the facility is properly designed, operated, and maintained,
can it achieve permit effluent limitations?" In addressing this question, the
reviewer must make sure that plans are included which meet O&M staffing and
training requirements. Unit processes must be operable, flexible, and
maintainable under projected load flow conditions. The discharge permit
requirements should also be included in the facility plan. The requirements
and influent characteristics will determine the type of monitoring and process
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control testing needed. The more complex the control testing requirements,
the more complex is the operation and maintenance of a treatment works.
The hydraulic arrangement has great impact on O&M. This must be
considered during the planning process. Poor hydraulic arrangement can
result in plant shutdown when only one unit needs repair. Arrangement
should allow for even distribution of influent among parallel units.
The impact of industrial waste should also be considered. The treatment
process is a biological one. Any toxic or unusual waste will disrupt the
process and result in poor plant performance. Pretreatment of industrial
waste may be necessary to prevent process failures.
Many designers overlook plant return side streams. These side streams
must be considered when designing a treatment facility. Return of
supernatant liquor, thickener overflow, and sludge will greatly affect BOD's,
total suspended solids, and nutrients. If these are not considered, the
NPDES permit limitation may not be met.
Pretreatment should be considered; in many instances, it will reduce the
operation and maintenance problems at a treatment plant. This must be
documented.
The plant design must be flexible enough to allow for different modes of
operation (e.g., an activated sludge plant may be operated as an extended
air or contact stabilization plant). This flexibility will assure continuous
operation and maintenance of the plant during flow and load changes, plant
expansion, and/or unit repair.
The influent characteristics should also be documented. The applicant
must provide sampling and analytical data used in the planning process. This
data determines the degree of treatment needed to obtain effluent limitation.
Therefore, the reliability of this data is important.
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The reviewing agencies should require docu-
mented proof that O&M costs were discussed during
the public participation phase of the plan of study.
To attract people's attention, a large printed notice
should be published. These notices should state the
cost of operating and maintaining the plant after
construction and the name of the funding institution or agency. It should be
made clear that, in applying for and accepting a construction grant, the
public accepts the responsibility to fund the operation and maintenance of the
wastewater treatment plant.
Many implementation agreements require careful consideration. Some of
these are administrative in nature and have no bearing on O&M. However,
there are several that have a direct or indirect effect on the operation and
maintenance ability of the applicant.
The funding of nonfederal costs should be reviewed. The financial
arrangements for funding nonfederal costs may severely limit the applicant's
funding ability for operation and maintenance.
User charges and debt-service charges should be considered in the
facility plan. Some questions that should be asked are:
1. What was the basis of these charges?
2. Are they realistic?
3. Were they used only to satisfy the public during the public partic-
ipation phase?
4. Will these charges fund proper and efficient operation and mainte-
nance?
These two charges need to be investigated completely. Funding for proper
operations and maintenance is dependent upon them.
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Last, but not least, is the applicant's past record of operation and main-
tenance of existing federally funded facilities (40 CFR 35.935-1, Grantee
Responsibilities). If the grantee is not providing adequate O&M at existing
plants, then appropriate action must be taken.
The reviewing agency must prepare a summary of comments and recom-
mendations for the applicant. These should be implemented by the applicant
prior to approval of the facility plan or before a Step 2 grant application is
accepted.
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PROBLEMS THAT MAY DEVELOP IF O&M IS
NOT CONSIDERED IN STEP 1
Operation and maintenance considerations may be overlooked when
planning a wastewater treatment facility. The lack of concern has created
many operation and maintenance problems for the operator. Major problems
that have developed are:
1 . Inadequate funding for O&M
2. Inadequate training for operators
3. Inadequate laboratory facilities
4. Nonexistent maintenance management programs
5. Useless O&M manuals
6. Inflexibility in the systems
7. Staffing difficulties
The lack of adequate funding for O&M is a major
problem. Utility owners (city officials and the
public) must provide the money needed to get the job
done. The applicant must be aware of the program
requirements for O&M funding (40 CFR 35.935-1,
Grantee Responsibilities). To meet these requirements the applicant must
make provisions for sufficient O&M funding. A user charge system must be
developed. If these O&M requirements are ignored, then adequate funding of
O&M is jeopardized.
Along with O&M funding, the training of operators is a problem. The
grantee should provide qualified trained personnel and pay adequate salaries.
This is impossible without knowledge of O&M requirements such as funding for
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pre- and poststart-up training as defined in PRM 11-2 and training as part of
the pian of operation (PRSVi 77-3). Additional training should be required to
strengthen the operator's skills. Without training, or with insufficient
training,, there is little chance for proper and efficient O&M to be achieved.
Another problem is the sack of laboratory facilities. Laboratory testing
procedures are necessarv to determine the efficiency of plant operation, and
to ensure compliance vkh ihe NPDES permit. Without these procedures, poor
operation practices may resi It. i'i addition, there is no way to monitor
NPDES permit cornplbno:,.
Operation ano ,-ai-v -"tipce also suffers when an effective maintenance
management program is not developed. If the operator does not know what
preventive maintenance is needed,, or when it is needed, it cannot be
performed properly. This program is pah. of the O&M manual requirements.
Early knowledge (prior to Step 1 appiication) of the need for an O&M manual
will provide an opportunity to establish an efficient maintenance management
program.
A system needs to be flexible. The operator must be able to make
changes in the operation of the treatment plant. If these changes cannot be
made, then O&M of the plant is impaired. This is an O&M requirement that
should not be omitted.
Staffing is another problem the applicant will face. For example, the
Imhoff tank with an oxidation porici may require a minimally skilled, part-time
operator, while the new wastewatai" treatment facility (an extended aeration
plant) would require several fu;!-time, highly skilled operators. The
applicant roust be able to sMract these operators in order to staff the
treatment works props:'1!-./. ', his >s r,ot always an easy task and often means
higher salaries for- 'no^a oeopic.
-------
The grantee faces problems, not only after the system \s on line, but
throughout the entire grant process. From the beginning of the grant
process, O&M concerns must be emphasized. If the applicant develops a plan
of study deficient in O&M concerns, the result will be delays in approval and
increased costs which the applicant has to fund. Not only would the plan of
study be faulty, but the applicant would not be aware of its responsibility for
O&M. Without knowledge of O&M requirements (user charges, funding of
O&M, etc.) the applicant may develop an erroneous cost/benefit analysis
which will result in improper plan selection. The applicant may select a plan
that will cause bankruptcy if the treatment plant is operated properly. The
plan selected may also call for trained operators that are not available to the
applicant. The problems alone would prevent the applicant from operating
and maintaining the treatment plant properly.
Plant size is often another problem. Influent characteristics (flows and
loads) used for planning and design must be documented. Undocumented
characteristics will result in a plant that is either oversized or undersized.
An undersized plant (hydraulically and/or organically) cannot be operated to
obtain the desired effluent. It will have to be modified to handle the influent
characteristics. Until these expensive modifications are made, the plant will
continue to produce a poor quality effluent.
An oversized plant will also create O&M
problems. The user charge to fund O&M may be
unrealistic. If everything at the plant is oversized
(labs, pumps, etc.) O&M costs will be excessive and
the plant will not be able to produce the desired
effluent due to underloading. Plans that have not
given proper consideration to flexibility may produce a poor quality effluent.
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Another important O&M requirement is the plan of operation. The
applicant must be able to develop a reliable plan of operation which includes a
statement of what must be done and when it must be done. This assures
proper and efficient start-up and continued operation. Early knowledge of
PRM 77-3 (Plan of Operation For Municipal Wastewater Treatment Facilities)
will enable the applicant to develop a usable plan of operation at the
beginning of the grant process.
Early knowledge of the O&M manual requirement is a must. The
applicant's design engineer should begin the project with the O&M manual in
mind. As the project progresses, a better design may be the result. A
better designed plant may eliminate many O&M problems. If the O&M manual
requirement is not discussed early, a poorly designed plant with an unusable
manual could be the result.
Improper start-up of the treatment works presents another potential
problem. This causes delays and problems in achieving operational objectives
which may take weeks, months, or years to correct. Some problems
associated with start-up are lack of trained personnel, development of unsafe
O&M procedures, inferior operation procedures, and improper operation of
equipment. The applicant must be informed early of PRM 77-2 so start-up
services can be planned from the beginning of the construction grants
process. From the facility plan comes the design phase and its plans and
specifications. Without O&M concerns, the design phase may result in a
process and control system that cannot be used to operate the plant
efficiently. The lack of O&M concerns will also result in the use of unreliable
equipment.
If O&M is ignored, or introduced late in the construction grants
program, many problems will develop. Every effort should be made from the
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beginning to expose the applicant to O&M program concerns in the
construction grants program. This will not eliminate all problems but it will
reduce the number and magnitude of problems.
2-30
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CHECKLIST
PREAPPLICATION CONFERENCE
O&M CONSIDERATIONS FOR DISCUSSION
1. O&M requirements are described in 40 CFR
35.925-10 (Operation and Maintenance Program),
40 CFR 35.935-1 (Grantee Responsibilities), and 40 CFR 35.935-12
(Operation and Maintenance).
2. Facility plans must include cost-effectiveness analyses that contain
evaluations of improved effluent quality attainable through optimum
operation and maintenance of existing facilities as an alternative or
supplement to construction of new facilities [40 CFR 35.917-1(b)].
3. Proper operation and maintenance of federally funded facilities is a
longstanding requirement [PL 84-660, Section 8(b); PL 92-500, Section
204(a)(4); 40 CFR 35.935-12]. Inadequate operation and maintenance
can cancel federal expenditures on facilities designed to abate municipal
pollution. Grantee may be ruled nonresponsible with respect to
applications of grants unless existing federally funded facilities are
adequately operated and maintained [40 CFR 35.935-1]. (Note:
EPA/state personnel should review grantee files to verify adequacy of
existing facility O&M.) Step 1 grants can be awarded conditionally
based on improved O&M. The scope of work for plans of study could
include early evaluation of existing facility O&M and recommendation of
necessary improvements. Upon completion of these improvements, Step 1
grants could then be awarded.
4. Grantee needs to document influent characteristics (flow and load) for
planning and design purposes.
5. Plans of operation must be prepared (40 CFR 35.935-12) and are grant
eligible (PRM 77-3).
2-31
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a. Preliminary plan must be submitted with plans and specifica-
tions [40 CFR 35.920-3(c)(3), Contents of Application].
b. Final plan must be submitted and approved before 50 percent
of the Step 3 grant payment is made (PRM 77-3).
6. O&M manual must be prepared (40 CFR 35.935-12).
Note: Writing should start when the design engineer begins.
a. Draft manual must be submitted by the time 50 percent of the
Step 3 grant payment is made.
b. Final manual must be submitted by the time 90 percent of the
Step 3 grant payment is made.
7. Planning for start-up services should begin early. Start-up services are
grant eligible (PRM 77-2).
8. User charge system must be developed.
9. Funding of O&M budget must be considered.
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PLAN OF STUDY
REVIEW OPERATION CHECKLIST
40 CFR 35.920-3(a)
CONTENTS OF APPLICATION
2. Entity or entities are identified to conduct the
planning.
3. Summary of the existing system is included.
4. Nature of the problem is stated.
5. Facility planning requirements are included.
6. Task statement, schedule, and cost are included.
7. Maps of planning areas are included.
8. Applicant displays both knowledge and under-
standing of all applicable rules and regulations
for preparing the facility plan (including all
O&M requirements).
9. Applicant shows an understanding of PL 92-500,
Sec. 204(a)(4), as amended.
10. The plan of study addresses the operation and
maintenance program requirements for a facility
plan.
11. Itemized costs are realistic.
12. Timetables are realistic.
13. Identified tasks will lead to a facility plan that
addresses O&M program concerns and complies
with all rules and regulations.
Signed
Date
a
CHECKLIST
YES NO N.A
1. Proposed planning area is included within
jurisdiction.
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FACILITY PLAN
REVIEW OPERATION CHECKLIST
Have existing facilities, as an alternative or
supplement to construction of new facilities, been
evaluated based on improved effluent quality attain-
able through optimum operation and maintenance
(40 CFR 35.917-1, Contents of Facilities Plan)?
NOTE: In responding to this question, the
reviewer should determine whether the following
factors have been considered:
a. Design vs. actual loading.
b. Treatment efficiency for each unit
process.
c. Treatment deficiency cause(s).
d. Maximum overall treatment efficiency
obtainable with existing unit processes.
e. Age, reliability, and probable useful life
of existing equipment.
f. Capabilities of existing staff and the need
for additional O&M personnel and upgrade
training.
g. Pretreatment ordinance (40 CFR 35.907,
Municipal Pretreatment Program, 40 CFR
Part 403, Pretreatment Standards).
h. I/I reductions.
i. Unit process modification(s).
j. Minor modifications (capital).
CHECKLIST
D __~ .
YES NO
NA
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YES NO NA
2. If properly operated and maintained, will the
proposed facility meet requirements for effluent
limits?
NOTE: In responding to this question, the
reviewer should determine whether the following
factors have been considered:
a. Plan provides for a sound and attainable
O&M program. ___
b. Plans are included for staff development
and training. _____
c. Requirements for staffing and training
will provide satisfactory O&M.
d. Staff from the existing facility is adequate
for operation of the proposed facility.
e. Operability and flexibility of unit
process(es) have been evaluated.
f. Discharge permit requirements and
influent, effluent, and process control
testing requirements have been deter-
mined.
g. Impacts of hydraulic, organic, industrial,
and inplant return side stream variations
have been evaluated.
h. Pretreatment program requirements have
been determined.
3. Is the plant design flexible enough to:
a. Allow for different modes of operation?
b. Accomodate future expansion and change?
c. Assure adequate operability and maintenance? ___
4. Has grantee documented (through sampling and
analytical data) the influent characteristics used
in the planning process?
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YES NO NA
5. Have O&M costs and revenues been adequately
evaluated 140 CFR 35.917-1(d)]?
a. What ,ire the total O&M costs? $
1 . Powec costs $
2. Chemical costs $
3. Parts and replacement
costs $
b. What dr-e the annual O&M costs to each user class?
1. Residential $
2. Industrial $
3. Other $
c. What are the available annual O&M revenues?
$
6. How has the grantee informed the public of the estimated O&M costs?
a. Total annual costs = $
b. Cost per household = $
Has grantee adequately operated and maintained existing federally funded
facilities [40 CFR 35.935-1]?
NOTE: If grantee is not providing adequate O&M at existing federally
funded facilities, responsive EPA operations include:
a. Determining grantee ineligible for Step 2 grant.
b. Basing award of Step 2 grant on the condition of improved
O&M.
c. Taking enforcement action as appropriate.
d. Providing or requiring onsite technical/training assistance in
conjunction with an enforcement action.
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e. Taking no specific action if O&M problems are determined to be
minor and/or not the result of grantee actions/inactions.
8. Summary comments and recommendations:
a. O&M of existing facilities
b. Considerations of O&M requirements in proposed project
c. Recommendation on facility plan approval
Signed
Date
2-37
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O&M
CONSIDERATIONS
STEP 2
CONSTRUCTION GRANTS PROCESS
UNIT
3
3-1
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UNIT THREE
OBJECTIVES
Following the Unit Three presentation the participant will be able to:
1. Recognize and discuss the phases in Step 2 of the Construction
Grants Process.
2. Determine and explain the O&M considerations that must be included
in the Step 2 application.
3. Identify and explain the O&M program requirements that must be
discussed at a predesign conference.
4. Evaluate operation and maintenance needs of the design of a waste-
water treatment facility.
5. Utilize various review techniques in the review of plans and specifi-
cations.
6. Determine that all O&M program requirements have been included in
the plans and specifications.
7. Utilize, in conducting a review, the information contained in EPA
MCD-05, Design Criteria for Mechanical, Electrical, and Fluid
System and Component Reliability.
8. Evaluate the plan of operation for O&M program requirement com-
pliance.
9. Discuss problems that may develop if O&M is not considered in
Step 2.
10. Identify and use the Operational Review Checklist in the Step 2
Application Review Predesign Conference, Plans and Specifications
Review, and Plan of Operation Review.
3-2
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UNIT THREE
OUTLINE
I. OVERVIEW OF THE STEP 2 PROCESS 3-4
A. Step 2 Grant Application
B. Predesign Conference
C. Plans, Specifications, and Estimates
D. Preliminary Plan of Operation
II. OPERATIONAL REQUIREMENTS IN STEP 2 GRANTS 3-7
A. Operational Considerations in Step 2
B. Operational Considerations at the Predesign Conference
C. Operational Considerations in Design
III. OPERATIONAL REVIEW OF PLANS AND SPECIFICATIONS 3-17
A. Plans and Specifications Review Techniques
B. Plans and Specifications Review Operation
C. Applicability of Technical Bulletin
IV. PLAN OF OPERATION 3-30
A. Requirements
B. Elements of a Plan of Operation
C. Plan of Operation Review Criteria
V. PROBLEMS THAT MAY DEVELOP IF O&M IS NOT CONSIDERED
IN STEP 2 3-40
VI. APPLICATION STEP 2 REVIEW OPERATION CHECKLIST 3-42
VII. PREDESIGN CONFERENCE O&M CONSIDERATIONS FOR
DISCUSSION 3-43
VIM. PLANS AND SPECIFICATIONS REVIEW OPERATION CHECKLIST 3-45
IX. PLAN OF OPERATION REVIEW OPERATION CHECKLIST 3-50
3-3
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OVERVIEW OF THE STEP 2 PROCESS
Step 2 Grant Application
The application package is reviewed and must be approved by the state
and/or the EPA. The grantee is not to proceed with any work on the project
until instructions to do so are received from EPA or the state.
An approved facility plan, as described under Step 1, is required as
part of the Step 2 application. If the facility plan has already been approved
by EPA or the state, only a copy of the approval letter must be submitted.
The application form is submitted by the authorized representative of the
territory included in the facility plan. In all cases, the applicant must have
the authority to design, finance, construct, operate, and maintain any result-
ing wastewater treatment facilities.
Contracts and subagreements for services are submitted by the applicant
and reviewed by both the state and/or EPA. At this point in the grant
process these are generally consulting engineering .services. Contracts and
subagreements are reviewed to determine that:
1. The scope of work is sufficient to prepare approvable plans and
specifications
2. Complete schedules are reasonable and in agreement with the facility
plan
Grantees are required to develop a user charge system which is appli-
cable to all users. This/sycem covers operation and maintenance costs of the
treatment works. At the time of application for a Step 2 grant, applicants
must submit a statement of resolution and a schedule for completing the user
charge system.
3-4
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(EPA may not pay more that 50 percent of the
Step 3 grant until evidence of the development of the
user charge is received. Also, no more than 80 per-
cent of the Step 3 grant may be paid until the user
charge is approved by EPA. The user charge must
be ready for implementation by the time the project is
completed. )
The grantee must develop an industrial cost recovery system. This is a
system which recovers from industrial users that portion of the federal grant
which is equal to the industry's share of capital cost of the project. The
grantee must assure EPA that all industrial users will be charged their fair
share.
A copy of existing sewer use ordinances, or a letter of intent stating
that such ordinances will be enacted, must be included in a Step 2 applica-
tion. The ordinance must require that new connections be properly designed
and constructed and free from storm water flow.
Projects which entail the acquisition of private property or the displace-
ment of persons are subject to the provisions of the Uniform Relocation and
Land Acquisition Policies Act of 1970. A Step 2 Grant Application must
include a statement assuring that the applicant will comply with the provisions
of this Act.
Predesign Conference
The applicant, engineer, state personnel, EPA, and the O&M specialist
should meet in a predesign conference.
All parties at the predesign conference should be keenly aware of the
necessity of considering O&M in the design of the plant. The knowledge of
an experienced operator should be relied upon heavily at this point.
3-5
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Plans, Specifications, and Estimates
The end product of the Step 2 detailed design is a set of plans, specifi-
cations, and detailed construction cost estimates which are suitable for
bidding and construction purposes.
Preliminary Plan of Operation
A plan of operation is required for all plants. The plan should include
a list of actions needed to ready the plant and its personnel for operation
when construction is complete.
3-6
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OPERATIONAL REQUIREMENTS IN STEP 2 GRANTS
Operational Considerations in Step 2
The consideration of O&M does not end with the approval of the facility
plan. The need to be aware of and able to implement O&M program concerns
extends throughout the entire construction grants program. There are
special O&M concerns that must be stressed in Step 2 of the grants process.
After approval of the facility plan the applicant may submit a request for
a Step 2 grant. This request is reviewed to determine that:
1. The name, project number, description of grant, and amount of
grant request agrees with state priority certification and state pri-
ority list
2. The form is signed by the authorized representative and a copy of
the authorization resolution is attached
3. A statement relative to availability of site is attached
4. Information regarding project location, entities involved, and cost
data corresponds to that in the facility plan
5. The applicant has proposed a method of financing nonfederal share
(including O&M costs)
6. All assurances are included in the application
There are several review techniques that must be used in the review of
a Step 2 application. These include an administrative review, a technical
review, and an operation review. These reviews are of equal importance and
can be conducted simultaneously. The primary concern is the operation
review.
Using the Application Review Operation Checklist, the reviewer can
ensure that the required O&IVl concerns have been considered in the Step 2
application. A sample checklist has been included in this unit for the partici-
pant to use in the review process. (Refer to page 3-42).
3-7
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The application must include a schedule or other evidence of compliance
with the O&M requirements of 40 CFR 35.925-10 and 40 CFR 35.935-12. This
schedule should also include provisions for the preparation of a preliminary
plan of operation (PRM 77-3). The cost of this preliminary plan should be
identified separately from other costs (PRM 77-3).
The application must contain proof that the applicant has legal authority
to design, finance, construct, operate, and maintain the waste treatment facil-
ity. This assurance is part of EPA Form 5700-25 and must be signed by the
applicant. If the applicant does not have this authority then the application
will be rejected.
The assurance statement also contains other O&M program requirements.
Upon signing this statement, the applicant agrees to comply with all regula-
tions, policies, guidelines, and program requirements. The statement specifi-
cally spells out certain O&M program requirements:
1. Sufficient funds must be available to assure effective operation and
maintenance of the completed facility.
2. The facility must be operated and maintained as required by
federal, state, or local agencies to meet required minimum stan-
dards .
The applicant must fulfill any additional requirements specified by the
Regional Administrator.
This assurance statement is a legally binding
document. It must be signed and included in the
application. It can be used to prove that the appli-
cant was aware of O&M requirements.
The application must also contain an approvable
user charge system which includes an implementation
schedule. The reviewer must ensure that this O&M requirement is met.
3-8
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If the project involves more than one political jurisdiction, then the pro-
posed service agreements must be reviewed. These agreements will affect the
funding of operation and maintenance. If these agreements are not included,
or do not address each political jurisdiction's responsibilities for enforcement
of the user charge and sewer use and rehabilitation ordinances, they should
be returned for clarification. These agreements have a direct effect on the
operation and maintenance of the wastewater treatment facility; therefore, all
responsibilities must be stated clearly.
The reviewer must ensure that the proposed contracts and subagree-
ments will result in approvable plans and specifications. This is more of an
administrative review; however, O&M will be affected if the scope and nature
of proposed services will not produce reliable plans and specifications.
The reviewer must ensure that the signature on the Step 2 application is
the same as the one on the Step 1 application. If not, then a new author-
izing resolution by the applicant is needed. In addition, the reviewer will
inform the new personnel of O&M program requirements.
Operational Considerations at the Predesign Conference
To ensure that plans and specifications are developed according to sound
engineering principles and program requirements, a predesign conference
should be held. This conference should be mandatory because of the com-
plexity of these requirements. It will promote planning, coordination, and
completion of the design phase. This conference may be held by EPA or the
state agency and should be tailored to fit the needs of the applicants.
At this conference, the reviewer should state all program requirements
as related to Step 2 applications. A suggested agenda may be found in the
USEPA, Handbook of Procedures for Construction Grants Program Municipal
Wastewater Treatment Works, MCD-03, February 1976, page V-11 to V-14.
Only those requirements for O&M will be discussed.
3-9
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A checklist titled "Predesign Conference, O&M Considerations for Discus-
sion" has been developed (page 3-43). The reviewer will find it helpful in
conducting a predesign conference on O&M concerns. In addition, the
reviewer can verify that all O&M concerns have been discussed at the pre-
design conference.
The reviewer must give careful consideration to the plans and specifica-
tions and must emphasize flexibility, operability, and maintainability of each
unit as well as of the overall facility. The mode of operation should be
readily changed as load and flow change.
The grantee must be made aware of 40 CFR
35.920-3(c)(3) (Contents of Application) and its
requirement for a preliminary plan of operation. The
reviewer should provide PRM 77-3 and explain it to
the applicant. Explanation of this requirement should
enable the grantee to understand and implement the
required preliminary plan of operation.
The reviewer needs to explain 40 CFR 35.935-12 to the grantee, includ-
ing the requirements for an O&M program, O&M manual, and staffing and
training. This should develop in the applicant a better understanding of the
need to start planning for an O&M program in the design phase.
The required emergency operating plan should be explained, including
the effects of emergencies, how vulnerable the system may be, protective
measures, and a response program.
The reviewer should place great emphasis on routing flow flexibility.
The plan and its unit must have flow routings that can be changed when
required in emergencies or for unit maintenance.
3-10
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The applicant must be notified of the need for process control develop-
ment, including tests, laboratory equipment, records, and qualified person-
nel .
In addition, the O&M budget should be discussed. The reviewer must
reaffirm this budget requirement and remind the applicant of the responsi-
bility for funding of this budget. At this time, the user charge and indus-
trial recovery cost should be discussed.
The required ordinances will also be covered. A sewer use ordinance
and a pretreatment ordinance are required to help ensure proper and efficient
operation and maintenance of the treatment facility.
A discussion of line item costs is required. Costs should be determined
for the following grant fundable items:
1. The plan of operation
2. Start-up services
3. O&M manual preparation
Documentation of influent characteristics should again be discussed as
plant design is based upon influent and effluent limitations.
The predesign conference is a useful tool and an important part of the
grant process. It can be used to make the applicant aware of program
requirements (especially those related to O&M), and to remind the grantee of
its responsibilities for proper and effective operation and maintenance of the
wastewater treatment plant.
Operational Considerations in Design
The design of a wastewater treatment facility will
greatly influence facility operation and maintenance.
t
The design sets the stage for operation and mainte-
nance needs and attitudes. The designer must always
be aware of the relationship between O&M and
plant design.
3-11
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There are many design considerations that will affect the operability of
the treatment facility. The reviewer should become familiar with these consid-
erations. This will enable the reviewer to perform the review function more
effectively and efficiently.
One of the first design considerations is the plant site. The site can
place many restrictions on the design. The availability or shortage of land
will affect the size, layout, and shape of the proposed facility. Future
expansion may be limited or impossible. Environmental restrictions may make
it impossible to operate or maintain the facility. For example, a plant in a
swamp or flood plain will have severe O&M problems. Natural limitations of
the site may create operational problems that cannot be overcome. Problems
in political jurisdiction of sites may arise. These also will have to be consid-
ered and resolved. In addition, the use of existing facilities may create O&M
problems and must be considered. Operational problems created by their
design may be carried over into the new plant. Site constraints that may
adversely affect operation and maintenance of the new facility must be con-
sidered and compensated for in the design.
The influent characteristics must be considered in the design of the
treatment facility. This is why documentation of flow and load was required
in Step 1. The objective of a wastewater treatment facility is to produce an
effluent of a certain quality. To accomplish this, the design must allow for
variation of influent flow and load. Of equal importance, when considering
flow and load is the effect of "recycled loads." Allowance for supernatant
liquor, sludge thickener overload, and other sludge liquor returns must be
considered. These returns will cause variations in flows and loads. The
design must be flexible enough to allow for efficient plant operation under all
load conditions.
3-12
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Plant size and its relation to simplicity and flexibility is an important
operational consideration in design. During the plant design process, alter-
natives are compared and a selection is made. The selected design should
minimize the number of unit operations required of the operator. This sim-
plicity of design must not result in operating headaches in the future. For
example, some designers have omitted grit chambers to reduce unit opera-
tions. This practice has led to many O&M problems after start-up. The
reviewer should use caution when reviewing for simplicity and flexibility in
design.
The layout of the plant must be done with O&M in mind. The placement
of plant components on the site will affect the staff's attitude toward the
wastewater treatment plant. Convenient and logical placement of plant compo-
nents can reduce the amount of time and work required to operate and main-
tain the treatment plant. In small plants a centrally located operation build-
ing can simplify plant operation. This central location allows for ease of
operation and maintenance for the operator. The operation can be controlled
from one building. In large plants, satellite operation centers may be
needed. The use of centrally located operation buildings or satellite buildings
reduces the complexity of operation for the operator. The simpler the opera-
tion, the better the operator will perform his/her duties.
Climate needs to be considered in the design of
a treatment plant. Substantial differences in design
will result from an appraisal of local climatic condi-
tions. The climate will affect drainage, component
housing, protection from wind, drying bed design,
materials used, and even the treatment process.
r r r r
r r r r
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Open drying beds may work in a West Texas town where evaporation is high,
but it would not work in areas of high rainfall. The design should consider
adverse weather and its effect on operation and maintenance. A design which
is not based upon climatic conditions, including inclement weather, will result
in operational problems at the proposed treatment plant. The reviewer should
ensure that the designer has considered the effects of climate in the design.
Another important operational consideration in design is materials hand-
ling. The designer must recognize this, and consider what will be involved
for the operator. The materials must be identified as to type, quantity,
shipment sizes, frequency of delivery, and residues to be removed. Unnec-
essary handling of materials should be avoided.
Plant hydraulic arrangement has a dramatic effect on plant operations.
The piping arrangement should be designed to allow unit removal without
causing a downstream or upstream unit removal. For instance, removal of a
settling tank should not cause the upstream aeration tank to be removed as
well. Flow routing should be flexible to allow for various modes of operation.
An example of this is to arrange piping to allow an activated sludge plant to
be operated as an extended air or contact stabilization plant. Piping should
allow for the equal distribution of solids and liquids. Pumping arrangements
should allow one pump to pump from one unit or from several units. In
general, the hydraulic arrangements should allow flexible operation.
Equipment selection has a major impact on plant operation and mainte-
nance. The need to control the quality and special features of equipment is
very important. Savings in capital outlay may be offset by increased opera-
tion and maintenance. The program requirement of "two brand names or
equal" may be causing the use of inferior products or equipment in waste-
water treatment plants. The plans and specifications should ensure that the
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equipment used is equal to the brand name in quality. This will reduce
possible O&M problems.
Design of a treatment plant should embrace the concept of flexibility.
Many factors which influence plant operation often change without warning.
Changes such as flow and load, staff capabilities, maintenance requirements,
and regulatory requirements create the need for plant flexibility. If the
design allows for operational changes then O&M of the plant should be easier.
Component reliability in design is a must. Duplicate or backup systems
need to be included in the design.
Safety in design is a very important consideration. It is necessary to
ensure that the operator has a safe environment in which to work. If opera-
tors feel that various operational duties are unsafe, then they will not per-
form the necessary O&M tasks. The reviewer needs to be aware of the impor-
tance of safety in the design process and in the review process.
Operational considerations in design are very important. In order to
provide for O&M considerations, the design should exhibit:
1. Flexibility: The ability to change modes of operation easily without
disrupting the process
2. Operability: The ability of the operation to produce the required
effluent under various flows and loads without disrupting the pro-
cess
3. Maintainability: The ability to perform maintenance tasks without
disrupting the process
4. Reliability: The ability to perform the designated function consis-
tently without disrupting the process
5. Durability: The ability to provide ongoing service without disrup-
ting the process
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6. Economy: The ability to produce the required effluent at the
lowest possible cost
The absence of any one of the above will reduce the operational performance
of the wastewater treatment plant.
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OPERATIONAL REVIEW OF PLANS AND SPECIFICATIONS
Plans and Specifications Review Techniques
To ensure that the facility to be constructed will meet effluent and
statutory requirements, a review of the plans and specifications is necessary.
Depending upon the complexity of the project, periodic reviews will be carried
out during the preparation of the plans and specifications. The time frame
for plans and specifications development can vary from one month to over a
year. Review meetings should be held with the project engineer during the
development of the plans and specifications, usually at the 25 percent, 50
percent, 75 percent, and 90 percent stages. During these review meetings,
an operational review should be conducted. This will enable the design engi-
neer to make corrections which will ensure effective plant operation and main-
tenance. The plans and specifications submitted for final review will include
all changes that result from the review meetings. The final plans and speci-
fications must undergo a rigorous review for all program requirements. This
review may take anywhere from two weeks to one or two months. The
reviewer has many responsibilities during this review. There are many
administrative and technical items that must be included in the plans and
specifications. All of these are important, but we are primarily interested in
effective plant operation and maintenance. Our review will focus on opera-
tional considerations which affect plant operation and maintenance. These
considerations will lead to better plant O&M.
An important step in successful plant operation is the preparation of
original plans and specifications. The review should ensure that the plans
and specifications meet the objectives of the treatment facility. They should
provide owner (operator) control over the contract or equipment supplies as
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well as the contractor or equipment supplier. They should be easily read and
understood. The standard operating procedure component sections should be
complete. These sections should protect the owner's (operator's) interest.
The contract document should clearly state the process performance specifica-
tions, performance testing, and process and equipment warranties. Most of
all, the process performance specifications and tests should provide for flexi-
bility of plant operation. The reviewer should ensure that these requirements
are met in the plans and specifications.
Plans and specifications have a significant impact
on the cost of operation and maintenance of the
wastewater treatment facility. They should translate
project requirements into the most cost-effective oper-
ating system for the owner. The plans and specifica-
tions must contain an explanation of the method of bidding and the basis for
evaluation and awarding of bids. It is a common assumption that the lowest
bid must be accepted. However, this is not true; EPA does not require
acceptance of the lowest bid. Federal requirements state that the award must
go the the lowest responsive, responsible bidder. The plans and specifica-
tions must contain guidelines stating how the bidder is to be selected.
The designer/reviewer should be able to recognize design defects that
have been responsible for poor operation and maintenance in the past. The
design must be tailored to the type of waste to be treated and must provide
for adequate capacity and operational flexibility. The reviewer should become
familiar with the engineering firm preparing the plans and specifications.
This firm should have qualified personnel available: (1) to provide start-up
service, operator training, and troubleshooting; and (2) to recognize design
problems and offer solutions for their correction.
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The reviewer must be aware of the function of each component of the
plans and specifications. For example: What is the function of a screening
device? Its purpose is to remove coarse materials that could damage or other-
wise affect plant operation and maintenance. The design of the screening
device varies with its application. When reviewing the design of the screen-
ing device, the reviewer must consider:
1. What is the size of particles to be removed?
2. What is the hydraulic loading?
3. What is the hydraulic gradient?
This capability can be a valuable tool in the review process. The reviewer
needs to be aware of the function and application of each component of the
treatment facility. This review procedure can then be developed to its fullest
potential.
The development of a feedback system can assist the reviewer in benefit-
ting from other reviewer's experiences. Incorporating these experiences will
greatly improve the review process. This feedback system should be de-
signed to identify new and improved review techniques for a more effective
review. No matter how experienced a reviewer may be, valuable input can be
gained from others' experiences. An important source of feedback information
is data gained by reviewing existing plants with design O&M problems and
their plans and specifications. The reviewer may then be able to prevent
new plants from having similar problems through changes in the plans and
specifications. A particular firm may continually repeat the same design
error. Use of an in-house memorandum would alert all reviewing personnel to
this reoccurring error. The use of a formal feedback system by reviewing
agency personnel is a valuable tool in the development of effective review
techniques. Such an approach will lead to better plans and specifications
which in turn will result in operable and maintainable treatment facilities.
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Plans and Specifications Review Operation
Along with the development of a review technique, the reviewer should
use the Plans and Specifications Review Operation Checklist. This checklist
(page 3-45) was developed as a guide for the reviewer. The reviewer must
ensure the consideration of O&M concerns in the plans and specifications.
The checklist will assist the reviewer in this process.
A design summary should be included with the plans and specifications.
This summary should include:
1. A flow diagram
2. A hydraulic profile
3. The point of discharge and identification of the receiving stream
4. The initial population equivalent and flow
5. The flow and load characteristics (BOD^, toxicity, etc.)
6. The design flow, population, and year
7. The design efficiency and effluent standards
8. The physical characteristics of treatment units
9. An identification and justification of deviations from standards,
guidelines, or technical bulletins
10. The sludge disposal method
11. An explanation of any unusual design feature
12. The quantity and type of industrial waste
13. The factors in design affected by industrial waste
14. The dimensions and volume of each process unit
15. The flow rate and volume within each process compartment for
minimum, average, maximum, and initial start-up flow
16. The expected BOD5, COD, and TSS in all side streams and mix
liquor returns
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17. The recycle rate
18. Any anticipated chemical additives
19. A diagram of piping showing flows, flexibility of flow, and hydrau-
lic profiles for minimum, average, maximum, and initial start-up
flows
20. A schematic of the physical controls for each process compartment
21. The BOD,-, TSS, and COD removal of each process compartment
22. A list of physical control and laboratory tests for each unit
23. Estimated staffing for start-up and point at which facility reaches
design capacity
The summary should also include data on the basis of design. This data
should be easily understood by the reviewer and should contain a description
of the project in terms of type of treatment, flow capacity, and unit process.
The basis of design should state the justification of need for the project.
This information lays the groundwork for the review process by explaining
the process, its purposes, and procedures. This information should be read
thoroughly by the reviewer.
There are many operational program requirements that must be included
in the plans and specifications. The reviewer needs to ensure that all
requirements are met. The reviewer should also look for operation and main-
tenance problems that may occur because of the design. An example of a
design flaw that may appear is the lack of metering in the return activated
sludge piping. Lack of meters limits the operator's control over the amount
of activated sludge which is returned. This may result in a loss of process
control. The reviewer must always be aware of the many design errors which
can occur.
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The plans and specifications must document, the flow and load character-
istics and should also include the effluent limitation. The design is based
upon this information. The type and extent of treatment to meet the effluent
limitation is keyed to the influent characteristics. There must be proof that
the data used is accurate; if it is inaccurate, the plant may not be able to
achieve its design purpose.
The plans and specifications must provide for operability, flexibility, and
maintainability under all anticipated flow and load conditions and throughout
the useful life of the treatment facility. To be operable and maintainable, the
design should:
1. Provide safe and easy access to all equipment valves, gates, and
other operating devices
2. Provide overhead cranes to lift major equipment and to move large
or cumbersome items to different levels. The reviewer should look
for obstructions that prevent use of the crane (piping running
across the track, etc.)
3. Provide a good working environment in the galleries and utility
tunnels; this includes drainage, ventilation, and light
4. Provide utility stations throughout the plant to ensure ease of
access to wash-down water, air, stream, potable water, etc.
5. Provide openings in the floor, roof, and walls for removal of large
equipment (cranes, or in some cases eyebolts for hanging chain
falls, should be provided for)
6. Provide room to work for the operation/maintenance personnel
These six items will make the operator's work easier by making plant
operation and maintenance easier. The design should allow the facility to
operate under various loads and flows without affecting the process. The
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operator must be able to remove and put back on-line any unit without dis-
rupting another unit or the entire plant. Flexibility, operability, and main-
tainability are all tied together. However, there is a fourth requirement that
affects the other three. The design must provide for the reliability of the
unit process and equipment. If a plant (or its components) is not reliable,
then plant operation and maintenance is next to impossible.
The plans and specifications must state the requirements for sampling
and process control equipment. Both the type and location of this equipment
must be specified. Equipment should be conveniently located and should allow
for efficient operation and maintenance. The process control and sampling
equipment will help provide maximum flexibility of operation. The selection
and location of equipment should be based upon:
1. Process requirements
2. Efficiency of each unit
3. Costs (initial and O&M costs)
4. Personnel capabilities
5. Maintenance needs
6. Facility expansion
7. Ease of access to control functions
8. Ease of performance of control functions
Process control equipment and sampling equipment selection must be consid-
ered in terms of plant operation and maintenance. The process control equip-
ment must provide operator control of the treatment process and must meet
the NPDES monitoring requirements. It should include such things as flow
meters, variable speed pumps, and alternative flow routing. The control
equipment should be located for safe operator access. Sampling equipment
and locations should be adequate to meet the laboratory control program
requirements of the wastewater treatment facility.
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The plans and specifications should include lab-
oratory facilities. These facilities must be adequate
to conduct analyses and monitoring of pretreatment,
influent, effluent, unit and plant efficiency, and pro-
cess control. They should include the necessary
equipment to conduct tests required by the NPDES
permit or by the state agency. In addition, they should contain the neces-
sary testing equipment needed for proper process control. A means of inter-
preting the results to the operator is needed as the terms used in conducting
and recording the results of the test may not be understood by all operators.
This data will help the operator perform the necessary functions to ensure
good plant operation. The locations for sample collection must be shown on
the plans and specifications. If the operator does not know where to take
samples, then the lab is useless to him. The reviewer needs to become aware
of the EPA publication "Estimating Laboratory Needs for Municipal Wastewater
Treatment Facilities." This bulletin contains guidelines for:
1. Physical facilities
2. Staffing
3. Unit process sampling and testing needs
4. Estimation of equipment and supplies
5. Examples that illustrate equipment needs
This bulletin should be used when determining if adequate laboratory facilities
are provided for in the plans and specifications.
The design must take into consideration the need for an emergency oper-
ating plan. Although the plan is contained in the operation and maintenance
manual, the design can provide one of the basic elements in an emergency
response plan. The design should provide a rapid and positive detection
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system, including alarms (with their own power source) that will warn of high
water, power failure, or equipment malfunctions. The specifications should
require that emergency operating instructions be furnished by equipment
suppliers. The designer can use this information in the development of the
O&M manual or to evaluate the equipment in terms of reliability and flexibil-
ity. This evaluation should be part of the O&M emergency plan. It will
enable plant personnel to respond more effectively lo
emergencies affecting the equipment. The design
should consider alternate power sources to be used
during a power outage. The plans and specifications
need to include a standby emergency power system
which would assume the load when a power failure
occurs. This standby system should be able to meet the required load.
Not only do the plans and specifications need to consider an emergency
operating plan, they should design for emergencies such as power outages,
equipment failures, flooding, etc. This would lessen the impact caused by
the emergency and improve plant operation.
Safety procedures and design must be considered in the plans and speci-
fications of the proposed treatment plant. Design safety considerations have
often been neglected in the plant design. Each stage of the design must take
safety into account. Many of the newly completed plants have had to be
modified to create a safe working environment. Safety planning is needed to
prevent unnecessary accidents and deaths. Section 204(a)(4) of PL 92-500
requires assurance of proper and efficient operation of facilities. Safety is
considered an integral component of proper and efficient facility operation. It
promotes operation and maintenance and helps to avoid needless shutdowns
and repairs which reduces O&M costs. In addition, it creates a better work-
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ing environment for operators and maintenance personnel. Operational func-
tions are improved because operators are not subjected to unsafe working
conditions.
Along with personnel safety, the design should consider the safety and
operation integrity of the equipment. It must be protected from hazards
(weather, vandalism, flooding, electric overload, etc.) which reduce its capa-
city to perform design functions.
The design must minimize operation and maintenance staffing and budget
requirements. An analysis must be made of the operation and maintenance
requirements for the proposed facility. The plans and specifications must
contain specific recommendations for staffing (including operator qualifica-
tions) and annual budget needs for the treatment plant.
The reviewer must verify that energy requirement criteria are included
in the plans and specifications. Use of the most energy efficient components
and unit processes will aid in the overall reduction of O&M costs.
The reviewer should be familiar with the staffing guidelines and should
be able to determine whether or not the design engineer's estimates are rea-
listic. This can be accomplished by comparing these estimates to those recom-
mended in the municipal wastewater staffing manuals.
Although start-up services are normally part of the Step 3 grant applica-
tion, planning for these services should begin early. Requirements for start-
up services have been discussed at both the preapplication and predesign
conferences. The design engineer must consider those things needed to
accomplish plant start-up. Plant start-up may be defined as a series of
events that lead to a stabilized, routinely controlled plant, process, or unit.
As the plans and specifications are being prepared, the designer should also
develop the start-up services.
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Applicability of Technical Bulletin
Reliability of unit processes and equipment must be incorporated into the
design to ensure continuous plant operation. To ensure the reliability of unit
components, EPA issued technical bulletin MCD-05 titled "Construction Grants
Program Requirements: Design Criteria for Mechanical, Electrical, and Fluid
Systems and Component Reliability," USEPA-430-99-74-001. This bulletin
specifies operational control requirements for treatment plant design.
Flexibility is the key word in the application of the criteria. This
criteria stresses component backup for reliability. However, the needed
degree of reliability may be achieved through design flexibility (e.g., alter-
nate flow routing and/or storage capabilities). The level of reliability usually
comes down to a matter of cost/benefit.
The bulletin defines reliability as "a measure of the ability of a compo-
nent or system to perform its designated function without failure." These
requirements pertain only to mechanical, electrical, and fluid systems and
components and their maintainability. Rigidity is minimized by the establish-
ment of three reliability classifications. The document does not specify
requirements for reliability classifications; however, it does define the three
classes. The required reliability class depends upon the impact of the treat-
ment plant upon the environment if the treatment process fails. The appli-
cant selects the reliability classification based upon the definition in the bul-
letin. The applicant must justify its choice to the regional administrator.
Design flexibility is achieved and rigidity is avoided by:
1. Having the different reliability classifications
2. Allowing alternative design criteria if supported by adequate tech-
nical justification
3. Specifying general design criteria and requiring the designer to
justify specific requirements applicable to the design
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This bulletin contains guidance on how to design for reliability in waste-
water treatment facilities. It is an important tool for the designer and the
reviewer. The reviewer should be aware of its contents and be able to use it
in the review process. This bulletin is a guide which contains the require-
ments for facility design.
New treatment works and additions or expansions to the existing treat-
ment works shall comply with these requirements. Portions of existing works,
for which the addition or expansion is dependent for reliable operation, shall
comply with these requirements to the degree practicable. There may be
some treatment works for which fulfillment of some of the design criteria may
not be necessary or appropriate. There will be other cases in which these
criteria are insufficient, and additional criteria will be identified by the
regional administrator. It is expected that additional criteria may be needed
for unusual environmental conditions and for new processes. Within this con-
text, the design criteria should be used as a reference, allowing additions or
deletions as an individual case may warrant.
A basic requirement specified in these criteria is component backup.
However, system reliability can also be attained through flexibility in the
design and operation of system and components. This document does not
attempt to define requirements for system flexibility.
The reviewer must be aware of the reliability classifications and their
requirements in order to conduct an effective review. In addition, the
reviewer must ensure that multiple units and equipment are provided to meet
the reliability classification set for the facility. The
design should allow for unit bypass which permits
continuous operation of other units if something hap-
pens to any one unit. The plans and specifications
should include some means of identification of all
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operating devices (i.e., valves, gates, drains, piping, etc.). If the operator
cannot easily identify a valve or piping, the component is not very reliable.
In determining reliability, the reviewer must make use of the information con-
tained in the technical bulletin MCD-05 (cited earlier). As the review contin-
ues, the reviewer will become more aware of this information and will be able
to use it more effectively.
The reviewer should look for the following items in determining treatment
facility reliability:
1. Two sources of electrical power
2. Standby power for essential plant units
3. Multiple units and equipment
4. Holding tanks or basin to provide storage for overflow and adequate
pump-back facilities
5. Dual chlorination units
6. Rapid mix of disinfectant with wastewater
7. Alarm systems
Inclusion of these design factors should allow for continuous plant operation
during emergencies, maintenance shutdown, and power failures. The
reviewer must ensure design consideration of plant reliability, flexibility,
operability, and maintainability. If these O&M concerns are met, then proper
and efficient plant operation and maintenance is likely to follow.
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PLAN OF OPERATION
Requirements
A plan of operation is required for all federally
funded wastewater treatment facilities. Guidelines for
the development of a plan of operation can be found
in Program Requirements Memorandum 77-3, Plan of
Operation for Municipal Wastewater Treatment Facili-
ties (PRM 77-3) and Federal Guidelines - Operation and Maintenance of Waste-
water Treatment Facilities, EPA, August 1974. The Federal Guidelines and
PRM 77-3 detail what should be covered by the plan of operation.
A plan of operation is a schedule of the steps and actions to be per-
formed at a later date to ensure cost-effective, efficient, and reliable start-up
and continued operation and maintenance of a wastewater treatment facility.
The plan identifies and schedules the tasks to be performed during start-up
and preparation of the O&M manual. It outlines the purposes, locations, and
time frame of each task and the staff responsible for each task.
A plan of operation may be divided into four general areas:
1. Administration, which includes staffing, personnel qualifications and
responsibilities, budget, and communication
2. Training of supervisory, operation, maintenance, laboratory, and
administrative personnel, including future training needs
3. Start-up services, which provide assistance and training before,
during, and after start-up
4. O&M manual, which is a written record of the first three activities
To ensure that operation is effectively considered in the three-step grants
process, the development of the plan of operation must begin early.
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Preparing the plan of operation begins in the facility plan of the Step 1
grants process which should include an outline of:
1. The staffing and training requirements for the proposed treatment
plant
2. The organizational structure, operating authorities, O&M budget,
and administrative control strategy
3. The control strategy for major unit(s) and for the entire plant
These three are the beginning of the plan of operation.
A preliminary plan of operation is required as part of the plans and
specifications. It specifically explains the three general areas of the facility
plan and also includes a preliminary implementing schedule. The preliminary
plan of operation should contain an implementation schedule for the develop-
ment of the following:
1. Staffing and training plans (training plans may be tentative)
2. Records, reports, and laboratory control systems
3. Process control and start-up procedures
4. Safety program
5. Emergency operating plan
6. Description of the maintenance management program
7. Development schedule for the O&M manual
8. Tentative operation budget
9. Tentative schedule of a sewer use ordinance:
a. Adoption
b. Pretreatment program
c. Industrial use ordinance
d. First completed annual treatment system O&M report
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The preliminary plan of operation should provide a schedule which includes
the following assurances:
1. A chief operator will be hired prior to 50 percent completion of con-
struction
2. The training program will be developed and started prior to start-
up
3. Staffing problems and solutions, if appropriate, have been consid-
ered
4. A list of positions and qualifications of personnel who are hired will
be prepared 30 days prior to start-up, with assurance that vacan-
cies will be filled
5. Start-up services are provided
The preliminary plan of operation should be submitted at the 50 percent
completion date of the plans and specifications. The reviewer should review
the plan of operation. If there are any deficiencies in the plan of operation
it should be returned to the applicant for necessary corrections or amend-
ments. A corrected final plan of operation should be submitted for state
and/or EPA approval when the design is 100 percent complete.
Fulfillment of requirements of Step 1 and Step 2 will make the plan of
operation a useful document in the Step 3 grants process. Step 3 implements
the plan of operation. The grantee is required by 40 CFR 35.935-12 to
submit timely evidence of implementing the requirements of the plan of opera-
tion for approval prior to 50 percent completion of construction. Unless
timely implementation of the requirements of the plan of operation has been
approved by the state and/or EPA, no more than 50 percent of the Step 3
grant will be paid. The grantee must show proof of compliance with the:
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1. Hiring of the chief operator
2. Development of the training program
3. Provision for possible staffing problems and solutions
4. Provision for a list of positions filled and qualifications of personnel
5. Start-up program requirements
6. Safety program
7. Draft O&M manual
A final O&M manual must be submitted to fulfill the requirements of a
plan of operation to receive 90 percent payment. Experience gained during
start-up must be used to make necessary modifications of the O&M manual.
This can be done before or after the 90 percent payment.
The completed items of the plan of operation should be evaluated during
the final construction inspection. The inspector should assess the completed
items and provide guidance for the design engineers on any incomplete item.
When all items are completed, the grantee should provide the appropriate reg-
ulatory agency with a summary of procedures for certification of completion.
The regulatory agency should evaluate and approve or disapprove the certifi-
cation after completing an O&M survey of the facility.
Elements of a Plan of Operation
A plan of operation should contain information on each of the following
areas:
1. Staffing and training
2. Records, reports, and laboratory control
3. Process control and start-up services
4. Safety
5. Emergency operating plan
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6. Maintenance management
7. Operation and maintenance manual
8. Operation budget
9. Other elements
More detailed information of these elements can be found in Federal Guide-
lines: Operation and Maintenance of Wastewater Treatment Facilities, August
1974.
Plan of Operation Review Criteria
The plan of operation is a schedule of actions needed to assure reliable
start-up and continued O&M of the treatment plant. It identifies and sche-
dules the tasks which must be performed as part of the start-up services and
preparation of the operation and maintenance manual. Program Requirements
Memorandum 77-3 contains an excellent example of a plan of operation and its
contents.
The preliminary plan of operation must be reviewed along with the final
plans and specifications. It should be complete, although some sections may
be tentative. The preliminary plan of operation must be approved prior to
the Step 3 grant approval.
All agency review personnel should recognize and use the review criteria
and the Plan of Operation Review Operation Checklist (included in this unit
on page 3-50). The criteria and checklist, which are designed as universal
forms, may be used for the review of the preliminary plan and the final plan
of operation. The complexity of a project will determine the detail of the plan
of operation. The reviewer must be able to recognize and properly use PRM
77-3 when reviewing a plan of operation.
The plan of operation must contain a chronological summary of implemen-
tation dates. The format of this summary is found in PRM 77-3 (pages 10,
11, and 12).
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The staffing and training plan assures that the necessary personnel are
hired and trained. Qualifications should be developed for each position.
There should be a provision made for hiring the chief operator by 50 percent
completion of construction. A training program will be developed which
includes the recommendations or requirements for state operator certification.
Records, reports, and laboratory control programs must be developed.
Records serve as a guide for plant operation and process control personnel to
help O&M personnel implement their duties. Records and reports are useful
aids in solving plant performance problems. State monitoring personnel can
use the records and reports to monitor plant O&M. The plan of operation
should require the development of implementation schedules for:
1. Adequate laboratory facilities
2. Adequate laboratory equipment and supply
inventory
3. Laboratory testing and process control
training
4. Defining laboratory training needs
5. Monitoring, sampling, and analyzing the program for each process
6. Influent and effluent monitoring for characteristics and removal effi-
ciency
7. Operating records
8. Special forms
9. Finalization of records and reports system
Consideration must be given to plant start-up and subsequent plant
operation. The plan should require process control reviews with plant per-
sonnel and explanation of start-up procedures. All equipment should be wet
and dry tested. The O&M manual will describe this section more thoroughly.
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A safety program must be provided in the plan of operation and should
provide scheduling for the development of an employee safety and health pro-
gram. Safety training programs should be developed and conducted prior to
start-up. Periodic safety training should follow.
A schedule for the development of an emergency operating plan develop-
ment schedule must be submitted with the plan of operation. This schedule
should include the following actions:
1. Development of details of the emergency operating plan, including
personnel assignment
2. Finalization of cooperative assistance agreements with other organi-
zations (fire, police, civil defense)
3. Prestart-up training
4. Initiation of annual procedures to update the employee training
program and the emergency operating plan.
To ensure uninterrupted treatment and reduce the possibility of plant
failure, a complete routine maintenance management program is needed. The
plan of operation should schedule the following actions to ensure that a main-
tenance management program is implemented:
1. Develop a schedule for routine preventive maintenance activities
2. Complete inventory of spare parts and maintenance tools
3. Conduct personnel training on O&M of specialized equipment by
suppliers (equipment manuals included)
4. Provide plant personnel with training on the maintenance manage-
ment system
5. Develop a maintenance record system
6. Begin prestart-up maintenance schedule
3-36
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The plan of operation should provide scheduling to ensure that an O&M
manual is developed. The plan of operation should provide training for oper-
ator use of the O&iVI manual. A provision for updating should also be includ-
ed in the O&M manual.
The plan of operation should include a schedule for preparing a sewer
maintenance program. This requirement, is not in PRM 77-3, but is in 40 CFR
35.935-12(6X7), (Operation and Maintenance), if the sewer system is subject
to inflow and infiltration, the plan of operation should include a schedule of
cost-effective steps designed to eliminate these inflow and infiltration sources.
This schedule should be completed prior to start-up. The sewer maintenance
program should:
1. Incorporate both corrective and preventive O&M
2. Reduce or eliminate inflow and infiltration
Any planning process must consider budgetary constraints. Since the
plan of operation is a planning process, it should address those constraints.
Budget considerations should include prestart-up and start-up and as a
minimum identify the operation and maintenance budget by category and cost
of each.
The plan of operation will ensure the following devel-
opments:
1. An estimated annual operation and mainte-
nance budget
2. A user charge system
3. An industrial cost recovery system
In some instances, pretreatrnent of wastewafer is needed prior to discharge
into the sewer system. The plan o1 operation must include a schedule of
those events necessary for the development of a pretreatment program. The
L
?-37
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Federal Guidelines titled "Construction Grants Program Information, State and
Local Pretreatment Programs," (EPA 430/9-76-017abc), MCD-43, (3 volumes)
contains data on types of pretreatment programs. The reviewing personnel
should possess these guidelines.
To assure continued efficient and reliable operation of the treatment
facility, certain actions are needed. The plan of operation should include a
schedule of events necessary to assure reliable operation such as:
1. Promulgation of a new sewer use ordinance
2. Promulgation of an industrial pretreatment ordinance
3. Promulgation of a sewer rehabilitation system
4. Development of user charge rate structure and ordinance
5. Development of an industrial cost recovery system and ordinance
6. Compliance with any state and/or local regulations not previously
covered
As stated earlier, "proper O&M of federally funded treatment works is a
must!" PL 92-500 Section 204(a)(4) states that the grantee must assure
"proper and efficient operation, including the employment of trained manage-
ment and operation personnel, and the maintenance of such works in accord-
ance with a plan of operation approved by the state water pollution control
agency..." This requirement is also in 40 CFR 35.935-12. Even if it was not
required by law, a plan of operation would still be necessary. It is an impor-
tant document in incorporating operation and maintenance considerations into
the three-step construction grants process. The plan of operation requires
careful review to ensure that all events, tasks, etc., are scheduled to
achieve effective and efficient start-up and proper operation and maintenance
during the life of the plant.
3-38
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A plan of operation is not a facility operating plan. It is a plan (or
schedule) for completing all O&M manual requirements. It specifies actions
which must be taken to accomplish operational efficiency as quickly as pos-
sible. The reviewer must assure that essential actions are described and that
the schedule for completion coincides with the projected construction and
start-up date of a Step 3 grant. This will provide advance assurance that
the treatment plant can achiev/e design criteria efficiency within a reasonable
time frame.
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PROBLEMS "THAT MAY DEVELOP
IF O&M IS NOT CONSIDERED IN STEP 2
O&M considerations may be overlooked when designing a wastewater
treatment Facility. Many O&M problems have been created by design errors.
Some of these problems are:
1. Lack of grit removal
2. Inadequate consideration of flow and load variations
3. Effects of climate
4. Hydraulic arrangement
5. Lack of hoists to remove pumps, large objects, etc.
6. Inefficient equipment placement
The absence of grit removal has become a problem in many small treat-
ment plants. In an effort to economize and reduce plant units, the process
of grit removal is often eliminated. This omission should cease. Grit will
take up space in aeration chambers and will have to be removed. This causes
plant shutdown and unnecessary expense.
The variation of influent flow and load must be considered. Many
designs do not consider flow and load at plant start-up. If the low flow at
start-up is not considered, many operating problems will develop. For
example, meters- may not register the low flow and pumps, blowers, chlorina-
tors, and other units may be oversized. Therefore, the designer must con-
sider all types of flows and loads when designing a wastewater treatment
facility.
The effect of climate on treatment process is often overlooked. There
are substantial differences in design approaches that result from various
climatic conditions. The designer must consider local climatic conditions, such
as adverse weather, when designing the wastewater treatment facility.
3-40
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Hydraulic arrangement resulting in different modes of operation must be
considered. Many designers have overlooked the importance of this. Design
flexibility will greatly improve plant O&M.
The operator and maintenance personnel face many problems if hoisting
equipment is not available. The ability to lift and remove pumps, motors,
etc., is a must. It is difficult and time-consuming to have to dismantle a
motor in order to get to a pump because there is no other means of removal.
The design must provide for some means of using hoists, etc., in the removal
of large, heavy pieces of equipment.
In equipment placement, the designer must consider:
1. The primary and secondary function of the equipment
2. Future plant expansion
3. Equipment controls location
4. The provision of working space for plant personnel
If the designer does not consider the above factors, then plant O&M is
impaired. Some examples of problems are: venture meters may become
clogged, pumps in deep pits may provide no maintenance or hoists for
removal, and control panel access doors may be located near the wall, making
access impossible.
Obviously, these are not all of the problems that can develop if O&M is
not considered in the design. However, these problems and others can be
prevented if O&M is considered in the design.
3-41
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APPLICATION STEP 2
REVIEW OPERATION CHECKLIST
40 CFR 35.925-10, 35.935-12
35.920-3(c)(3)
Does the application include a schedule or
evidence of compliance with O&M requirements
(40 CFR 35.925-10 and 35.935-12) including
preparation of a preliminary plan of operation?
Is the cost of the preliminary plan of operation
separately identified?
Has there been a change in application personnel
since application for the Step 1 grant?
If yes, have new personnel been informed of O&M
program requirements?
Recommendation on Step 2 grant award:
CHECKLIST
YES NO
NA
Signed
Date
3-42
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PREDESIGN CONFERENCE
O&M CONSIDERATIONS FOR DISCUSSION
1. Plans and specifications must emphasize operability, flexi-
bility, and maintainability of each unit process and of the
a
CHECKLIST
overall facility. A matrix on major design errors is being developed by
the Municipal Environmental Research Laboratory and should be used
when it becomes available.
2. A Preliminary Plan of Operation must be submitted with plans and speci-
fications; 40 CFR 35.920-3(c)(3); 40 CFR 35.925-10; 35.935-12;
(PRM 77-3).
3. Staffing and training analysis:
The facility must be designed to operate effectively with the minimum
number of O&M staff. Considerations include:
a. Availability and skills and existing facility personnel
b. Additional personnel and skills needed
c. Personnel training needs prior to plant start-up
4. Emergency operating plan should cover the following as a minimum:
a. Effects of emergencies
b. Vulnerability analysis of the system
c. Protection measures
d. Emergency response program
5. Flexibility on routing flows is necessary to permit:
a. Process control
b. Maintenance of process units
c. Emergency operation
d. Process control proceeding
3-43
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e. Sludge disposal
f. Sampling procedures
g. Effluent standards
6. A preventive maintenance program, including a records system, is to be
designed and initiated prior to facility start-up.
7. Influent, effluent, and process control laboratory testing, including
sampling locations, is to be established.
8. Operating budget, user charge, and industrial recovery system are
required and must be available.
9. Start-up service requirements include a subagreement proposal (e.g.,
for consultant services) which is drafted for submission with the Step 3
grant application (PRM 77-2).
10. Sewer use ordinance requirements should be discussed.
11. Pretreatrnent ordinance requirements should be discussed.
12. Line item costs must be determined for:
a. Plan of operation preparation
b. Start-up services subagreement
c. O&M manual preparation
13. Periods of raw sewage bypassing and other facility treatment disruptions
which violate discharge permit conditions must be avoided during new
facility construction.
14. Influent characteristics must be documented for design purposes.
NOTE: Conferences should be required.
If no predesign conference is scheduled, send this list to grantee
along with the Step 2 grant offer letter.
All information covered in the preapplication conference should be
reviewed again.
3-44
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PLANS AND SPECIFICATIONS
REVIEW OPERATION CHECKLIST
1. Has a design summary been included in the
plans and specifications?
2. Has an organized, systematic, basis of design
been provided?
3. Has grantee confirmed the influent character-
istics (flow and load) used for design purposes?
4. Do the plans and specifications adequately
provide for operability, flexibility, and main-
tainability under all anticipated flow and load
conditions (e.g., organic, industrial, seasonal,
and in-plant side streams) over the useful
life of the facility (including start-up)?
NOTE: A matrix on major design errors will be used.
This matrix is being developed by the Muni-
cipal Environmental Research Laboratory.
5. Has reliability of unit processes and equipment
been considered adequately?
a. Are means of assuring continuous operation,
including alternative sources, provided?
b. Have multiple units and equipment been
provided to the maximum extent possible?
c. Can individual plant units be bypassed?
d. Are there adequate provisions for flexibility
of operation?
CHECKLIST
YES NO
NA
3-45
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YES NO NA
e. Is the treatment process suitable for the
character and volume of the sewage to be
treated?
f. Are all operating devices, including valves,
gates, drains, pumps, motor starters, switches,
sensors, gauges, recorders, fans, heaters,
chlorinators, piping, manholes, etc., numbered,
labeled, or otherwise identified in a manner that
can be utilized and incorporated into the oper-
ation and maintenance manual?
6. Have the location requirements for process control
equipment and sampling equipment been defined
adequately?
7. Are the planned laboratory facilities adequate for
pretreatment, influent, effluent, process control,
and monitoring and analysis?
8. Has the need for emergency operating procedures
been considered?
9. Have plant safety requirements been met?
a. Is the plant fenced or otherwise enclosed?
b. Is the plant area well-lighted to provide
safe nighttime operation?
c. Is the public water supply protected by a
backflow preventer?
d. Is mechanical ventilation provided where
required?
e. Are railings and machine guards provided?
f. Are liquid chemical storage areas properly
curbed to hold the stored volume of liquid
chemicals in each area?
g. Is drainage from chemical storage and work
areas adequate?
3-46
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YES NO NA
h. Is adequate ventilation provided in areas
where chemical mist or dust might be present?
i. Are chemical piping or transporting systems
labeled and provided with splash guards and
other devices for protection of operating
personnel?
j. Is an eye wash fountain and/or safety shower
located within 25 feet of each location where
hazardous chemical exposure might occur?
k. Is a continuous and adequate supply of potable
water available for all eye wash fountains and
safety showers?
I. Will an audible alarm system be activated
when an eye wash fountain or safety shower
is in use?
m. Are all chemical storage containers properly
labeled?
n. Are chemical storage areas cool and dry?
o. Are separate areas provided for chemicals
which react violently with each other?
p. Is adequate and appropriate storage space
provided for all safety equipment (i.e. masks,
goggles, etc.)?
q. Are adequate and appropriate storage facilities
for emergency first aid equipment provided in
close proximity to each hazardous area?
r. Are adequate and appropriate signs posted in
all areas where hazardous chemicals are stored
or used?
s. Is an adequate number of appropriate fire
extinguishers provided?
10. Has facility been designed to minimize O&M staffing
and budget (including energy requirements) consis-
tent with satisfactory performance? (How does the
project plant staff compare with recommendations
from POTW staffing manual?)
3-47
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YES NO NA
11. Have start-up service requirements been adequately
considered?
12. Has a preliminary plan of operation been submitted
and approved? (40 CFR 35.925-10 and 35.935-12)
NOTE: Ref. PRM 77-3 to assess the following:
a. Do elements II through V and VII have
essentially complete descriptions and
schedules?
b. Is the staffing plan of I completed?
c. Is the training plan of I tentative?
d. Are tentative descriptions and schedules
for VI, VIM, and IX provided?
13. Has provision been made for a user charge system
to fund operation and maintenance?
14. Summary comments and recommendations:
a. Are plant (unit process) design and equipment
specifications adequate with respect to operabi-
lity, flexibility, and maintainability?
b. What progress has grantee made in meeting O&M requirements?
c. What are the recommendations for plans and specifications approval?
YES NO NA
d. Have O&M costs been considered for the following?
1) Salaries
2) Energy needs/costs
3-48
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3) Chemical costs
4) Parts and supplies
e. Does the budget need to be revised?
Signed
Date
3-49
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PLAN OF OPERATION
REVIEW OPERATION CHECKLIST
(for Preliminary and Final Plan of Operation)
CHRONOLOGICAL SUMMARY OF IMPLEMENTATION
DATES
STAFFING AND TRAINING (Schedule Provided?)
(Dates for implementation)
a. Identification of personnel requirements
b. Hiring of chief operator by 50 percent
completion of construction
c. Hiring of other operation and maintenance
personnel
d. Hiring of management personnel
e. Identification of and provisions for training
needs (basic, upgrade, and start-up)
RECORDS, REPORTS, AND LABORATORY CONTROL
(Schedule Provided?) (Dates, etc.)
a. Adequate laboratory facilities completed
b. Adequate laboratory equipment installed and
supplies inventory on hand
c. Development of laboratory testing/process
control training
d. Development of laboratory training needs
defined
e. Development of appropriate monitoring,
sampling, and analysis program for each
process
f. Development of a program to confirm influent
and effluent characteristics and removal effici-
encies (suggest influent sampling begin at
50 percent completion of construction)
CHECKLIST
YES NO
NA
3-50
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YES NO NA
g. Development of plant operating records to be
filed with proper state and federal agencies
h. Development of plant process control records
i. Development of special forms and records
j. Finalization of records and report systems
4. PROCESS CONTROL AND START-UP PROCEDURES
(Schedule Provided?) (Dates, etc.)
a. To be described in operation and maintenance
manual
b. To be updated in revision of O&M manual
based upon actual operation experience
obtained during plant start-up period
5. SAFETY PROGRAM (Schedule Provided?) (Dates,
etc.)
a. To be described in operation and maintenance
manual
b. Safety training to be given as a part of start-
up training
6. EMERGENCY OPERATING PLANT (Schedule Provided?)
(Dates, etc.)
a. To be described in operation and maintenance
manual
b. To be updated in revision of O&M manual
based upon actual operation experience
obtained during plant start-up period
c. Emergency operation procedures training to be
given as part of start-up training
7. MAINTENANCE MANAGEMENT PROGRAM (Schedule
Provided?) (Dates, etc.)
a. To be described in operation and maintenance
manual
3-51
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YES NO NA
b. To be updated in revision of O&M manual
based upon actual operation experience
obtained during plant start-up period
c. Maintenance management training to be
given as part of start-up training
8. OPERATION AND MAINTENANCE MANUAL PREPARATION
(Schedule Provided?) (Dates, etc.)
a. An operation and maintenance manual will be
developed pursuant to Public Law 92-500 in
accordance with applicable rules and regulations
b. Operation and maintenance manual revision or
update after plant has been placed in operation
and plant process reaction has stabilized
c. Instruction in operator use of O&M manual to
be given as a part of start-up services
9. SEWER MAINTENANCE PROGRAM
10. OPERATION AND MAINTENANCE BUDGET REQUIREMENTS
(Schedule Provided?)
a. Prestart-up budget
b. Start-up budget
c. Identification of operation and maintenance
budget by category
1. Salaries and wages
2. Operation
3. Utilities
4. Chemical (used for operational purposes)
5. Maintenance
6. Training
7. Upgrading and raises
8. Grounds maintenance
3-52
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YES NO NA
9. Laboratory costs
10. In-house contracting
11. Outside contracting
12. Contingency fund
13. Total operation and maintenance budget
d. Establishment of procedures for the prepara-
tion of an annual O&M budget report including
staffing, training, budget planning, maintenance,
and future construction
e. User charge rate structure
f. Industrial cost recovery usage for O&M budget
10. PRETREATMENT PROGRAM DEVELOPMENT (Schedules,
if required)
11. OTHER ELEMENTS
a. Promulgate new sewer use ordinance
b. Promulgate industrial pretreatment ordinance
c, Sewer system rehabilitation
d. Development of a user charge rate structure
and ordinance
e. Development of an industrial cost recovery
system and ordinance
f. Compliance with any state/local regulations
not previously addressed
12. RECOMMENDATION ON PLAN OF OPERATION APPROVAL
Pursuant to CFR 35.925-12
Signed_
Date
3-53
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O&M
CONSIDERATIONS
STEPS
CONSTRUCTION GRANTS PROCESS
UNIT
4
4-1
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UNIT FOUR
OBJECTIVES
Following the Unit Four presentation, the participant will be able to:
1. Recognize and discuss Step 3 of the Construction Grants Process.
2. Identify and discuss operation and maintenance requirements in the
Step 3 application.
3. Explain the responsibilities of each participant in the preconstruction
conference.
4. Recognize and explain the operation and maintenance payment conditions
of:
a. O&M manual
b. User charge system
c. Industrial cost recovery system
d. Sewer use ordinances
e. Sewer system rehabilitation program
5. Recognize and explain the purposes for O&M manual development.
6. Determine and discuss the contents of the O&M manual.
7. Utilize the review criteria and checklist during O&M manual evaluation.
8. Discuss problems that may develop if O&M is not considered in Step 3.
4-2
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UNIT FOUR
OUTLINE
I. OVERVIEW OF THE STEP 3 PROCESS 4-5
A. Step 3, Application
B. Step 3, Construction
C. Receipt and Review of Bids
D. Award of Construction Contracts
E. Preconstruction Conference
F. Onsite Inspections
II. OPERATIONAL CONSIDERATIONS, STEP 3 4-7
A. O&M Requirements in the Step 3 Application
B. Plans and Specifications
C. Plan of Operation
D. EPA Application Form
E. Contracts, Subagreements, and Completion Schedules
F. Proof of Compliance
G. Development of O&M Manual and Budget
H. Staffing and Training Plan
I. Start-up Services
OPERATION CONSIDERATIONS FOR PRECONSTRUCTION
CONFERENCES 4-11
A. Objectives of Preconstruction Conference
B. Responsibilities of Grantee
C. Responsibilities of Inspector
D. Responsibilities of Reviewer
IV. O&M CONSIDERATION PAYMENT CONDITIONS OF STEP 3 4-15
A. Schedule of Payment
B. Submission of O&M Manual
C. Submission of User Charge System
D. Submission of Industrial Cost Recovery System
E. Submission of Sewer Use Ordinances
F. Submission of Sewer System Rehabilitation Schedule
V. O&M MANUAL DEVELOPMENT 4-18
A. What is an O&M Manual?
B. What are the Purposes of an O&M Manual?
C. When is an O&M Manual Prepared?
4-3
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VI. O&M MANUAL CONTENTS 4-22
A. Elements of an O&M Manual
B. O&M Manual Guidelines
VII. O&M MANUAL AND THE OPERATOR 4-29
A. Operator Needs in O&M Manuals
B. Operator Problems With O&M Manuals
VIII. REVIEWING THE O&M MANUAL 4-33
A. The Audience
B. Improving oCmmunication
IX. O&M MANUAL REVIEW CRITERIA 4-36
B. O&M Manual Review
X. PROBLEMS THAT MAY DEVELOP IF O&M IS NOT CONSIDERED
IN STEP 3 4-51
XI. APPLICATION STEP 3 REVIEW OPERATION CHECKLIST 4-52
XII. PRECONSTRUCTION CONFERENCE OPERATION CONSIDERA-
TIONS FOR DISCUSSION 4-56
XIII. OPERATION AND MAINTENANCE MANUAL QUALITY
EVALUATION REPORT 4-58
XIV. O&M MANUAL REVIEW OPERATION CHECKLIST 4-59
4-4
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OVERVIEW OF THE STEP 3 PROCESS
Step 3, Application
The Step 3 application should include:
1. Application form
2. Service agreements
3. UC/ICR system schedules
4. Sewer rehabilitation schedule
5. Plan of operation schedule
Both the state and/or EPA must approve the Step 3 application.
Step 3, Construction
After the state and/or EPA has approved the application it will authorize
the grantee to advertise for bids. Grantees must circularize the proposed
project as widely as possible in order to get the maximum number of bidders.
Receipt and Review of Bids
Bids must be sealed and opened publically. The grantee will review the
bids and prepare a recommendation for award. Bid documents are then
forwarded to the state and/or EPA for approval.
Award of Construction Contracts
After the state and/or EPA has received and
reviewed the bid information it will authorize the
awarding of the contracts. At the time of the award,
a preconstruction conference should be scheduled.
Preconstruction Conference
The grantee, contractor, state agency, and EPA may hold a precon-
struction conference. Subjects to be discussed include the foilowing O&M
Considerations:
4-5
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1. O&M manual
2. Start-up services
3. Plan of operation
4. Staffing and training plan
5. Operating budget
6. Sludge disposal
Onsite Inspections
The state, EPA, and/or Corps of Engineers may conduct onsite project
inspections. These onsite project inspections are made during construction
(interim) and at the completion of the project (final).
4-6
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OPERATIONAL CONSIDERATIONS
STEP 3
O&M Requirements in the Step 3 Application
The application package includes many O&M items. An Application
Review Operation Checklist has been developed to confirm that all O&M items
have been completed (refer to page 4-52). The reviewer should conduct a
preliminary review of the Step 3 grant application utilizing this checklist.
Following the preliminary review, an indepth review is conducted which
further ensures that all items affecting operation and maintenance are includ-
ed and specific action is proposed by the applicant which will assure prompt
and efficient O&M of the wastewater treatment facility.
Plans and Specifications
The application must include approved plans and specifications. The
reviewer should confirm that the plans and specifications have been approved.
Plan of Operation
The applicant must also include an approved preliminary plan of opera-
tion. A completion schedule for the development of the final plan of operation
is required. The cost of the final plan of operation must be identified as a
separate item. This will enable the reviewer to determine if the cost of the
final plan of operation is reasonable and if provision for funding approval can
be made. The proposed scope of work must be able to achieve efficient
start-up and continuous plant operation. The reviewer must ensure that the
completion schedule will lead to an approvable plan of operation. The applica-
tion must also include an acceptable architectural-engineering subagreernent or
method of award for the preparation of the final plan of operation. The
reviewer must check this agreement to make sure it will lead to an approvable
final plan.
4-7
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EPA Application Form
The reviewer must be aware of O&M concerns and their relation to EPA
Application Form 5700-32. This serves as the formal application for a con-
struction grant. In addition, it states necessary grant qualifications includ-
ing the applicant's assurance that it will satisfy all statutory requirements.
This form must be signed by an authorized representative of the applicant
and show that the applicant has the legal authority to finance, construct,
operate, maintain, and collect revenues needed for O&M. A properly execu-
ted assurance form states that all statutory requirements (including those
listed in 40 CFR 35.935-12) will be complied with.
Contracts, Subagreements, and Completion Schedules
Proposed contracts and Subagreements will be submitted by the appli-
cant. These will be reviewed by both the state and/or EPA to ensure that
the scope and nature of the proposed services are sufficient to construct
approvable facilities. Proposed completion schedules must be reasonable and
in agreement with the plans and specifications and the plan of operation.
The reviewer should check to see if the fees to be charged by the contractor
are reasonable.
The application will also include the following items which may have an
effect on O&M program requirements:
1. Sewer use ordinance
2. Operation and maintenance scheduling
3. Sewer system rehabilitation scheduling
4. Institutional agreements
5. User charge system
6. Industrial use ordinance
4-8
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7. Pretreatment ordinance
8. Industrial cost recovery system
Proof of Compliance
Proof of compliance with 40 CFR 35.920-3(c)(3) Contents of Application,
40 CFR 35.925-10 Operation and Maintenance Program, and 40 CFR 35.935-12
Operation and Maintenance must be furnished by the applicant. Grant pay-
ments will be limited until these requirements are complied with.
If the Step 3 grant includes a sewer system rehabilitation program, a
completion schedule must be submitted. This schedule must be reasonable for
the work involved, because it must be complied with before full grant pay-
ment can be made.
The applicant will have jurisdictional control over all political entities in
the service area. This is necessary to assure adoption and enforcement of
the ordinances, user charge, and industrial cost recovery system. Without
this control, proper and efficient operation and maintenance becomes impos-
sible.
Operation and maintenance of the wastewater treatment facility must be
budgeted for. The applicant must submit an approvabie user charge and
industrial cost recovery system.
The applicant must also submit evidence of the development of an indus-
trial use ordinance and a pretreatment program ordinance. These are needed
if there are industrial users discharging toxic or incompatible waste which
requires pretreatment prior to discharge into the collection system. These
ordinances may be part of the sewer use ordinance.
4-9
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Development of Q&M Manual and Budget
The applicant must provide a schedule for the development of an O&M
manual. The cost of preparing this manual must be shown separately and be
easily identified from other costs.
The applicant must submit an estimated O&M budget including expected
costs and revenues for the first year of operation. The reviewer should
determine if the budget is adequate for the project.
Staffing and Training Plan
A staffing and training plan must be submitted as part of a Step 3
grant. It must provide a schedule for the hiring of staff and implementation
dates for training programs. In addition, it must include a salary schedule
and training budget which will attract qualified operators and fund a reliable
training program.
Start-Up Services
The application should include a provision for start-up services and an
acceptable subagreement or intended method of award for start-up service.
The reviewer should then schedule a preconstruction conference with the
grantee, engineering firm or consultant, contractor, the state, and EPA.
This conference should be held prior to construction.
4-10
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OPERATION CONSIDERATIONS FOR PRECONSTRUCTION CONFERENCES
Objectives of Preconstruction Conference
A preconstructlon conference should be held with the grantee, the
grantee's consultant, the contractors, the state, the EPA, and the inspector.
The objective of a preconstruction conference is to discuss the responsibilities
of each party in the project.
Preconstruction conferences are not mandatory. For the construction
grants program to be effective this conference should be held. The precon-
struction conference provides the final opportunity to discuss program
requirements prior to construction. It gives the regulatory agency another
chance to reemphasize O&M requirements. It will serve as a means to intro-
duce program requirements to new personnel (contractors, mayors, city
managers, etc.).
When conducting a preconstruction conference the reviewer should keep
account of the operational considerations covered at the meeting. Precon-
struction Conference Operation Considerations for Discussion Checklist has
been developed to aid the reviewer in covering the required O&M considera-
tions (refer to page 4-56). Utilization of this checklist ensures that O&M
concerns are considered in Step 3 projects.
Responsibilities of Grantee
The grantees should be advised of their respons-
ibilities to comply with all state and local laws and
ordinances. They may believe their only respon-
sibility is to comply with federal program require-
ments, but they must be aware of their responsibil-
ities to comply with all local, state, and federal laws
both in the construction process and in subsequent plant operation.
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The grantees must have an approved preliminary plan of operation.
This should have been part of the final plans and specifications and the Step
3 grant application.
The grantees must have submitted a start-up proposal for approval if
grant participation is desired. This is necessary to assure funding eligibil-
ity.
The grantees will be informed of the submission requirements for comple-
tion schedules of:
1. The final plan of operation
2. The draft O&M manual by 50 percent payment
3. The final O&M manual by 90 percent payment
4. Staffing and training
a. The chief operator should be hired by 50 percent completion of
construction
b. The training program should be developed and implemented
prior to start-up
These items must be approved by the regulatory agency.
The grantees must be informed of the requirement for submission of:
1. A user charge system
2. An industrial cost recovery system
3. A sewer use ordinance
The reviewer should explain each ordinance and how it affects O&M.
Funds for O&M can come from the user charge system and industrial cost
recovery system.
The sewer use ordinance prevents new sources of inflow, regulates new
connections, provides for pretreatment if needed. This ordinance helps to
assure proper plant performance by reducing and eliminating new sources of
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inflow, hydraulic and organic loading, and possible sources of wastewater
harmful to the treatment process.
The reviewer should discuss 40 CFR 35.935-8, Supervision. This section
requires the grantees to provide and maintain competent and adequate engin-
eering supervision and onsite inspection during construction. The grantees
must have their own inspector to assure that construction conforms to
approved plans and specifications.
The grantees must be aware of their responsibility to maintain sewage
treatment during the construction of new facilities. The reviewer should
explain that the passage of raw sewage must be prevented. The construction
of new facilities does not relieve the applicant of the responsibilities for
sewage treatment since these responsibilities are continuous.
The grantees must provide ongoing protection and maintenance for equip-
ment in storage, during construction, and before and after start-up.
The influent characteristics upon which the design criteria were based
must be confirmed. This is a responsibility of the grantees. Sampling and
analysis of the influent should begin early (no later than 50 percent comple-
tion of construction). The reason for this is obvious. IT the influent
characteristics upon which the plans and specifications were based were
wrong, there still would be time to correct the design criteria.
Responsibilities of Inspector
Wastewater treatment facilities constructed with
federal funds are subject to inspection by the state,
EPA, and/or Corps of Engineers. The grantee should
be made aware of this by the inspector or reviewer.
The reviewer or the inspector, if possible, should
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explain the who, why, what, when, and how of the inspection process. The
grantee should be reminded that although interim and final inspections are
made, others may be conducted.
Responsibilities of Reviewer
The reviewer should remind the grantee that the
treatment facility must be constructed according to
approved plans and specifications. Project changes
must be approved by the state and/or EPA prior to
being executed if they: (1) alter the design or scope of the project, (2)
alter the type of treatment, or (3) require additional federal funds. Changes
resulting from minor errors in the plans and specifications or changes of an
emergency nature do not require prior approval. All changes, no matter how
minor, should be noted.
Finally, the reviewer should restate the responsibilities of the grantee to
properly and effectively operate and maintain the wastewater treatment plant.
Special attention should be given to 40 CFR 35.935-1 Grantee Responsibility.
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O&M CONSIDERATION PAYMENT CONDITIONS OF STEP 3
Schedule of Payment
Generally, Step 3 grant payments are made according to a payment
schedule which is included in the grant agreement. The grantee must
request payment on form 2550-16 and supply support documentation. EPA
will review this form and authorize payment as appropriate. However, the
grantee must fulfill the O&M requirements before full payment will be made.
Submission of Q&M Manual
The grantee must submit a draft O&M manual. No more than 50 percent
of the federal share may be paid until this is accomplished. No more than 90
percent payment may be made until the final O&M manual is approved by the
state and/or EPA (40 CFR 35.935-12).
Submission of User Charge System
A user charge is a charge levied on users of a treatment works, or that
portion of the ad valorem taxes paid by a user for the user's proportional
share of the operation and maintenance cost (including replacement). The
grantee must have submitted a schedule for the development of a user charge
system during Step 2. During Step 3, the grantee must begin to develop the
user charge system. The system must meet the objective of distributing O&M
costs among all users in proportion to their waste load. The user charge
shall be based upon volume, flow rates, and strength of the wastes of all
users. The cost of O&M must be equitable to each user or class of users.
The user charge system should bring about operational self-sufficiency.
Submission of Industrial Cost Recovery System
Public Law 92-500, Section 204 (b)(1)(B) requires that the grantee
develop and implement an industrial recovery system. This system provides
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the means by which industrial users repay the proportionate federal share of
the construction cost of a publically-owned treatment facility. The cost shall
be recovered by the grantee during the useful life of the facility or within 30
years, whichever is less.
The grantee must:
1. Identify personnel responsible for the development of the industrial
cost recovery system by 50 percent payment of the Step 3 grant
and submit a detailed completion schedule for the industrial cost
system.
2. Submit a description of the industrial cost recovery system by 80
percent payment of a Step 3 grant.
Submission of Sewer Use Ordinances
The grantee must submit a sewer use ordinance and other legally binding
sewer use requirements for approval by the state and/or EPA by 80 percent
payment of the federal share of a Step 3 grant. These ordinances can
include a sewer use ordinance, an industrial use ordinance, a pretreatment
program ordinance, or a combination of all three. These ordinances must
assure that no new sources of inflow are connected to the sewer and that new
connections are properly designed and constructed. In addition, the ordi-
nances may regulate the type of waste discharge, require some type of pre-
treatment, require permits by industrial users, and provide for disconnection
and its penalty.
These ordinances should provide the mechanism for controlling all dis-
charge of waste into the sewer collection system. This is necessary to pre-
vent disruption of the treatment process.
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Submission of Sewer System Rehabilitation Schedule
In the Step 1 application process, the applicant determines by an inflow
and infiltration analysis and sewer system evaluation survey if a rehabilitation
program is necessary. If rehabilitation is necessary, the applicant must
submit a sewer system rehabilitation schedule. This schedule must detail the
completion dates of the work needed to correct the inflow/infiltration condi-
tions. Completion dates should be reasonable for completion of work prior to
start-up. If rehabilitation is deemed unnecessary, the applicant need only
submit written assurance that no excessive inflow and infiltration exists.
No more than 80 percent of the federal share of a Step 3 grant may be
paid before the rehabilitation program has been complied with.
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O&M MANUAL DEVELOPMENT
What Is an O&M Manual?
When a wastewater treatment problem has been
carefully studied, several solutions are considered.
The final solution is selected after evaluating al! of
the alternatives. Then the facility is designed to
solve the wastewater pollution problems. This design
is based upon influent characteristics and the desired effluent quality.
The designer has definite and specific objectives for each unit and each
process of the treatment facility. These design objectives can only be
achieved if the plant operator and the owner know and understand the design
objectives and effectively operate the wastewater treatment plant to meet
them. Using a properly prepared O&M manual is the most effective way of
informing the plant operator and owner of the designer's objectives.
An O&M manual is a document that provides simple necessary instruction
to operating personnel while listing the daily tasks necessary to achieve the
design objectives. The manual must explain the reason for the system,
identify each unit and its function, and tell how each unit's performance
affects the performance o\ all other units in the system. From this explana-
tion, the operator will understand the system and the need to operate the
plant as a unified system to achieve optimal performance.
The manual must clearly explain, as simply as possible, the operator's
responsibilities and duties of operating and maintaining the treatment plant to
continuously achieve high effluent quality within the budget limitations set by
the plant's owner. It must explain the plant process and provide overall
process control guidance. In addition, the manual should explain the daily
routine procedures needed to ensure proper plant performance. The
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and
o ;^"_.c,-prr3i,:;d ^-.to an overall operation
•• A;re il-nt '3'l \asK'. needed for proper
effeciVv":'-
by plant operation and
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., r,....
KV ''. 'i s snore than 50 percent
.!-, i :-.n!es> the grantee has
,-" ;-'>jj rite nance manual for
:'.-ve!« ; merit of such a draft,
• , , ..; ^ha'-e unless grantee
.••.-• r.ion arid maintenance
. i -'- fiijizn tc r-egion and from
>"; , the phrase "evidence of
;.,-crceni payment even when
; > Je-yelopsnent of the O&M
1 .;" ih= final O&M manual
:r the design engineer
i :-.nuai preparation are for-
., -,'„•• i6 ioft. The designer
-------
may not be able to correct design deficiencies during the design phase.
Instead (since the plans and specifications are already approved) the time-
consuming and costly change order procedure must be used. Sometimes it is
too late to make changes. As a result many changes that could make the
facility more operable, flexible, and reliable in meeting effluent standards are
not incorporated into the facility design.
O&M manual preparation should begin at the same time the facility plan
(Step 1 grant) is being developed. Much of the information included in the
facility plan is also included in the O&M manual. The appropriate sections
(permit and standards, personnel, laboratory testing, utilities, and emergency
operating plan) could be prepared to serve dual functions of meeting the
facility plan and the O&M manual requirements. Since the facility plan is an
engineering report, some editing and format changes would be needed.
However, the changes needed could be minimized if the sections are prepared
for maximum dual use.
The preparation of the O&M manual should begin no later than the pre-
paration of the plans and specifications. In preparing plans and specifica-
tions, the design engineer designs the entire wastewater treatment plant in
detail. The design engineer must assure that flexibility has been considered
to the utmost in the design by considering all requirements for pipes, gates,
meters, valves, flow channels, etc. If a description of each step envisioned
by the design engineer for facility operation was prepared and explained at
this time and an explanation was given of why each unit was included, then
the process controls and operational procedures of the O&M manual for the
facility would practically be written. The process controls and operation
procedures will need to be finalized when specific equipment is selected and
installed.
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Developing the O&iVi manual concurrently with the plans and specifica-
tions will identify unique operational requirements. This enables the designer
to develop-) specif icaiiors accordingly, results in tighter and better specifica-
tions, and assures that design and operational requirements are met. Editing
will be needed for a readable and usable O&M manual.
During preparation of piarts and specifications some portions of the O&M
manual Cdn be cornpieied, such as schematic drawings and the O&M budget.
When this is coiriplercci.. ihe rac.uirernsnt for a plan of operation is essentially
finished.
Prior to the construction phase, irsosl of the O&IVI manual should be
completed. Final couches can be made during construction to ensure that the
final manual reflects "as built" condir.ions. Editing for operator readability
and the addition of more detailed information produces a readable and usable
manual.
When the final O&M manual lias been drafted, submitted, and approved,
final payment can be made. The O&M manual requirement has not been met
until the manual has been tested, carefully reviewed, and updated after plant
start-up and operation. Any defects should be noted and corrective action
taken. An O&ivl manual mu^i be subject to change if it is to be a useful
reference
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O&M MANUAL CONTENTS
Elements of an O&M Manual
The manual should contain useful information for
the plant operation and maintenance personnel. The
writing style and format should be easily understood
by the operator. Any data not directly related to
facility operation and maintenance should be summarized in the appendices of
the manual.
As a minimum the manual should contain:
1. An introduction
2. A permit and standards section
3. A simple description of the operation and control of the wastewater
treatment facilities, including sludge treatment and handling
4. A description of personnel requirements
5. A laboratory testing section
6. A records section
7. A maintenance management section
8. An emergency operation and response program
9. A safety program
10. A utilities section including electrical power sources
11. An appendices of helpful information
The introduction or overview should introduce the entire wastewater
treatment system to the operator. It should present broad concepts of the
treatment system and introduce the treatment plant's overall performance
objectives. This section should describe the type of waste treated and its
sources and the sewer system and its possible problems. This description
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should not be lengthy, but should inform the operator of the type of raw
wastewater that will be treated and how to cope with sewer system-induced
problems.
The overview should describe the wastewater treatment process in great
detail covering flow patterns for both solids and liquids in the plant, identi-
fying and explaining the different components and processes in treatment of
wastewater and sludge, and giving the performance objectives of each unit.
The design engineer should explain why the particular treatment sequence
was chosen over other alternatives. The overview must stress the importance
of operating the treatment facility as a complete system rather than individual
units, explaining how each unit process works, and its relation to other
processes. The operator must realize the importance of keeping each compo-
nent functioning properly if the treatment plant is to achieve its performance
objective.
Operational flexibility, including flexibility of flows and modes of opera-
tion, should be covered in the overview. It should be stressed that opera-
tional flexibility can be used to maintain a consistently high quality of efflu-
ent.
The overview should also include the operator's goals and responsibilities
to ensure continuous effective plant operation. The purpose of the goals and
responsibilities should also be included in this section. The operator's impor-
tance as a water quality and health protector must be stressed. The over-
view should also briefly discuss the regulations, permits, and standards that
apply to the treatment facility. These should be presented in a manner that
establishes compliance with permits, standards, and regulations of the opera-
tor's responsibility for proper and effective operation and maintenance.
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The permits and standards section is written for the plant operator, but
city officials and the public should also be considered when writing this
section. The section can be used to convey the importance of the plant
operation and maintenance staff and the need of continuous upgrading of
operating skills through training.
The manual must explain each unit process in terms of operation, pro-
cess control, and maintenance which is perhaps the most important part of the
O&M manual. The explanation of each unit process given in the overview is
expanded in this section to include:
1. Process description
2. Operation principles
3. Process control procedures
4. Preventive maintenance
5. Process troubleshooting
6. Emergency operation and maintenance
A complete description of the process must be given including the pro-
cess characteristics and how they relate with other processes. A schematic of
the processing unit with three-dimensional drawings showing piping of all
flows and utilities should be included. Several drawings may be needed. All
related equipment (pumps, gauges) should be described in detail. The impact
of improper unit operation on the other processes should be emphasized.
Explanation of the operation principles is important so the operator will
know what is to be done, how to do it, and why it is done.
The O&M manual should include background and theory that is easily
understood by the operator for correct operation and control of the process.
Additional references, which contain a complete and detailed explanation of
the theory of wastewater treatment, can be provided in the appendices to the
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O&M manual. It is imperative for the operator to have complete understand-
ing of wastewater treatment principles in order to operate the treatment
facility properly and effectively.
One of the operator's most important duties is process control. This
section of the O&M manual must be carefully prepared and should be as
complete as possible. The operational procedures should be described in
great detail. It is important to present process objectives in the simplest
terms for the operator to understand. Specific data for each process objec-
tive should be presented in a step-by-step procedure for the proper opera-
tion of the process. Process control guides must include a detailed descrip-
tion of the characteristics of a properly operating system including both
laboratory characteristics resulting from sampling and testing and the sensory
observations by the operator. This information will help the operator to
determine if the process is operating properly.
The process control description should include a section on trouble-
shooting presenting:
1. Problem indicators
2. Probable causes
3. Determination of the cause by sampling, testing, monitoring
4. Corrective actions
5. Cross-reference to other sections in O&M manual
6. Possible references if an explanation is needed
This guide will assist the operator in recognizing a problem and determining
the necessary corrective action.
The manual should include a description of routine maintenance proced-
ures for each process. The maintenance procedures, either simple or com-
plex, should be described in a step-by-step manner identifying tasks that the
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operating staff can do and those they should not do. When including the
manufacturer's literature, care must be taken to assure that it meets the
operator needs. The writer should extract data that covers only the equip-
ment used in the facility. This section should also describe and discuss
emergency operating and maintenance procedures for each process. The
information in the maintenance section should be easily understood by the
operator.
The O&M manual should include the following information on personnel:
1. Staffing plan for facility
2. Work organization plan
3. Shift and weekend staffing scheduling
4. Organizational structure
An essential part of the personnel section is a training plan. All training
needs must be identified. The training budget should be equal to a sum of
three to seven percent of the total Q&M budget.
There should be a section on laboratory requirements explaining the
laboratory needs, personnel requirements, and type of sampling, testing, and
monitoring programs. All process control tests should be explained in a
step-by-step procedure. Sampling procedures should be explained. One
common weakness in this section is the lack of explanations of the results.
The operators can run the control test, but if they do not know what the
results mean, the procedure is wasted. The operator must recognize the
need to compare the test results to other tests. The benefits of the use and
interpretation of trend charts should be discussed in the O&M manual. The
value of using process control test results to improve plant efficiency must be
stressed. A complete record of the test results should be kept.
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Another section of the O&M manual explains the facility records and
recordkeeping system. Laboratory results are a small part of the records
needed at a treatment plant. The records that are kept depend upon opera-
tion and maintenance requirements and legal requirements. All forms needed
should be identified and included in the manual.
The wastewater treatment facility needs to have a maintenance manage-
ment system. The manual should describe and explain the particular system
recommended for the facility in terms that can be understood by the plant
operator. The benefits of a preventive maintenance program must be pointed
out. The operator must be aware of the need to correctly perform all routine
and preventive maintenance functions on a regular basis. The manual should
include a maintenance checklist of items to be done, when to do them, how to
do them, and how often they must be done.
Emergency operation procedures should be discussed in various sections
of the O&M manual. However, the manual must contain an emergency
response program to anticipate a variety of situations and present a response
action for each emergency situation. There are several EPA publications
providing adequate guidance on developing emergency response programs.
The manual should include training programs or dry runs which are needed to
inform the operator of the emergency response program and his/her responsi-
bilities.
An important section of the O&M manual is safety. The wastewater
treatment industry has a very poor safety record. An aggressive, effective
safety program must be emphasized in the O&M manual. Even though safety
is interwoven throughout the manual, a safety section is necessary. The
manual should establish safety procedures for all operation and maintenance
procedures performed. It should list, describe, and explain the use of all
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required and/or needed safety equipment. A safety training program should
also be included in the O&M manual.
The O&M manual needs to contain a utilities section with a separate
discussion of the complete system. The description should include the loca-
tion (wire size, pipe size, etc.)/ routine maintenance, and responsibilities of
plant staff or outside contractor. This section should include emergency or
alternate utilities which need to be identified and located. The manual should
describe the equipment that is and is not connected to the emergency or
alternate utility. AH procedures involved in changing from the normal utility
system to the emergency system must be described including a step-by-step
procedure of going from one source to the other.
Finally, the O&M manual should contain appendices which include all
material that may be useful to the plant operator. This material is usually
more detailed and complex than the manual itself and can be used by the
operator as a reference for help in performing responsibilities properly.
Q&M Manual Guidelines
The EPA's publication, Considerations For the Preparation of Operation
and Maintenance Manuals, provides extensive guidance on the contents of an
O&M manual. An outline for an O&M manual is included in the document
(pages 14 through 38). This document contains extended noi'es and comments
on each suggested chapter of the O&M manual. The appendices contain some
excellent reference documents that all regulatory agency personnel need to
improve their review. Use of this document will aid the preparer and re-
viewer in assuring that a usable O&M manual is produced that meets the
requirements.
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O&M MANUAL AND THE OPERATOR
Operator Needs in O&M Manuals
From the operator's point of view, the manual should be divided into at
least four sections. Each section would cover a specific topic: administra-
tion, plant operation, maintenance, and laboratory procedures.
The first section should be administration. This section would include
an introduction, requirements and/or responsibilities of management, staffing
personnel, operator training, public relations, permits and standards, safety,
budget and costs, and an emergency operating and response program. This
section would mainly be for administrative personnel but should also be avail-
able to plant operation and maintenance personnel.
The next section should cover plant operation. It must describe the
operation of each process as it relates to the entire system. Operational
procedures for normal, alternate, and common problems should be described
in a step-by-step procedure. The control process as well as the process
control test should be covered in detail, yet should be easily understood by
the operator.
A section on maintenance is needed which should include detailed inform-
ation on planning and scheduling, preventive maintenance programs, an
equipment records system, a parts inventory system, lubricants and house-
keeping, and maintenance personnel requirements. The various parts of this
section must be explained fully and in a format that the maintenance per-
sonnel can understand.
The last section will contain information on laboratory procedures. This
section should include a detailed description of the sampling, testing, monitor-
ing, records, reports, and personnel requirements. This section should also
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include information on interpretation of test results. An explanation of the
value of a data analysis sheet for determining trends is needed. This section
should inform the operator of what type of results are expected from testing
as well as what observations are expected of the treatment process.
In addition, the O&M manual should include a simplified diagram of all
piping, valves, and controls, including enlarged detailed drawings of compli-
cated piping areas. In many instances pictures should be included.
The manual should contain a schematic of the flow diagram of the treat-
ment plant, not only for the wastewater flow, but for all flows such as air,
gas, sludge, water, chlorine, potable water, etc. The manufacturer's daily,
weekly, and monthly maintenance schedules should be summarized and cross-
referenced to the page or pages of the manufacturer's manual.
Operator Problems with O&M Manuals
There are numerous problems with O&M manuals which range from format
to lack of detail.
Many manuals are not usable because they do not provide the necessary
data for the operator to operate the wastewater treatment plant. The
reviewer and many O&M manual authors do not consider the needs of the
operator. The operator should be able to use the manual as a reference on
process control, maintenance procedures, troubleshooting, operating instruc-
tions on all equipment (pumps, motors, etc.), laboratory procedures, orienta-
tion to the plant, and as a training tool. Many O&M manuals do not meet this
operator need and even when this need is met there are usually other
problems that the operator faces in using the manual.
Some common operator problems with the manual are complex language,
no instruction, only theory information, poor format, and lack of availability.
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Many manuals are too complex for the operator. The data contained is
for engineers, not operators, because the manuals are written by engineers
and reviewed and approved by engineers with little concern for the user.
Since many operators have less than a high school education the language may
be too complex for them. Some may have had operator training, but others
have not. The language used in an O&M manual must be simple, clear, and
instructive to assist the operator in learning about the treatment plant. Any
technical words or expressions must be cleariy defined. Manuals should be
written with step-by-step procedures for all operation and maintenance tasks
to be performed.
In many instances the manuals are too lengthy which causes the operator
to lose interest. The operator must be able to relate to the contents of the
manual. The manual must be written for the specific wastewater treatment
facility in which the operator works. General information and theory should
be minimized and placed in a separate section from the operating data.
In order for plant operation and maintenance personnel to find the
necessary information, the manual must be indexed so the information will be
easy to find. Tabs on each section and subsection would be helplul in locat-
ing the information without going through the entire manual.
Availability of O&M manuals is another problem faced by plant personnel.
Sometimes the manual is in the superintendent's office or another inaccessible
location. If the manual is not available, it cannot be used. This could be
solved by providing several copies for each facility or providing smaller
"pocket-sized" copies that would be readily available to the user.
Through better communication with the plant operation and maintenance
personnel, the engineers can produce a manual that can be understood and
used by everyone. The manual should provide understanding, techniques,
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and references necessary to effectively operate and maintain the facility. The
manual must be tailored to a specific plant and its equipment. The O&M
manual is a reference book and must be flexible. The information in it must
be changed and updated as time passes.
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REVIEWING THE O&M MANUAL
The O&M manual review requires knowledge of
the treatment process, itsfunctions and controls. The
reviewer should consider the operator and the opera-
tor functions and responsibilities. The reviewer
should evaluate the O&M manual to ensure that all
requirements and operator needs are met.
The Audience
The target audience or user of the O&M manual must be identified. The
audience may seem to be the operator, but this is not always the case.
The education, qualifications, skills, and background of the primary
users of the O&M manual must be taken into consideration by the reviewer.
The manual should be compatible with each user's skills and qualifications.
The contents of each section, its details, etc., will also depend upon the user
of the manual. The manual will be used as a guide for the expected job
procedures; therefore the user must be identified, with determination of skills
and reading levels to meet his/her needs. Achieving proper operation and
maintenance will be difficult if the O&M manual cannot be read and understood
by the user.
Improving Communication
There are many ways to improve the readability and usability of the O&M
manual. One of the best ways is to simplify the language. The reviewer
must consider two vocabularies when reviewing an O&M manual: technical and
general.
A technical vocabulary has words and terms which are of a technical
nature but are common and essential to the wastewater field. These words
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and terms must be in the manual, but each should be carefully defined when
it is first used. Simplifying the language does not eliminate any of the
technical terms but gives judicious and consistent use and proper definitions.
The general vocabulary has a simplified reading level which will make
O&M manuals easier to read. This can be accomplished without any loss of
technical details or information. Efforts to simplify the vocabulary are time-
consuming but must be done if the O&M manual is to be readable. There are
several word lists that can be used as a guide to predict the readability of an
O&M manual. The reviewer should obtain one of these lists for use during
the review of the O&M manual.
One example is the Clarence R. Stone Revision of the Dale Word List
which contains approximately 1,000 words. According to Stone, the words
are easily recognized by 80 percent of all fourth graders. The list was
developed as an overall statistical device that can give a reliable prediction of
the readability level. Using this list as a guide, the reviewer can determine
the level of readability by determining the percentage of words used in the
O&M manual that are not on the list.
Simplifying language is one way of improving readability in O&M manuals.
In addition, the author should use simple sentence structure. Even the
simplest vocabulary is difficult to read when long complex sentences are used.
Complex sentences usually contain multiple ideas or concepts, while simple
sentences contain one basic thought. Variety can still be achieved through
the use of simple sentences and at the same time readability levels will be
improved.
The use of illustrations (diagrams, charts, graphs, pictures, etc.) will
clarify and simplify written information. The text must be correlated with
specific illustrations.
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The table of contents, index, and appendices make the manual more
usable. An index enables the user to locate information easily while the table
of contents divides the manual into sections. A subject index in the appen-
dices is also helpful. Ease of information location greatly influences the level
of use. Each section of the manual should pertain to one particular subject.
The O&M manual is the operator's principal source of technical informa-
tion on the operation and maintenance of the wastewater treatment. The
manual must be tailored to each plant and should be easy to read, brief, and
concise. A well prepared O&M manual that is easy to read and use, that is
brief, available, and routinely used by the operation and maintenance staff
will help assure proper and efficient operation and maintenance of the treat-
ment plant.
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O&M MANUAL REVIEW CRITERIA
Q&M Manual Submission
The O&M manual must be submitted for review and approval. A draft
O&M manual must be submitted by the 50 percent payment date of a Step 3
grant. The final O&M manual must be submitted and approved by the 90
percent payment date of a Step 3 grant.
O&M Manual Review
The draft O&M manual should be reviewed as soon as possible in the
Step 3 process.
The O&M manual checklist was designed to be applicable to all projects.
Therefore, some of the items on the checklist may not be applicable for a
specific project. Review criteria have been prepared for each subject on the
checklist. The agency reviewer must be familiar with all review criteria
before completing the checklist.
The checklist is designed in a two-part review and evaluation: (1) style
and format and (2) content. The reviewer must consider the importance of
both parts. When reviewing the O&M manual for operator usability (i.e.,
style, format, content, language, etc.), the reviewer should use the following
criteria:
Review Criteria: Style and Format
1. Language:
State certification requirements for educational levels, if any, should be
considered. O&M manuals should be clearly written at a language level
which is meaningful to required O&M personnel. Simple sentences should
be used when possible.
2. Adaptation:
It is imperative that each individual facility have an O&M manual pre-
pared for its specific needs and requirements. By being plant specific
the information presented in the manual can be applied directly to the
appropriate facility.
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3. Sections:
O&M personnel, administrators, and consultants differ greatly in their
use of specific information included in the O&M manual. Manuals are of
limited use to operators if they are bulky and unmanageable.
Sections written specifically for certain units of individual facilities
should be furnished for individual operator use.
Therefore, division of the O&M manual into sections is strongly recom-
mended.
4. Materials for Inclusion:
Textbook and standard material should not be included in the manual.
This material should be referenced and available. A full set of as-built
plans should be supplied to the grantee. These plans are not included
in the O&M manual. Only those items which pertain to the specific
facility should be incorporated into the manual.
5. Scope of Manual:
Manuals being written for the upgrading and/or expanding of an existing
facility must address the operation and maintenance of the whole system
(i.e. both existing and new facilities).
6. Updating the Manual:
O&M manuals should be open-ended, dynamic documents prepared in such
a way that revisions are allowed to be made without difficulty.
Review Criteria: Content
The following criteria should be used when reviewing the O&M manual for
content:
1. Introduction:
An O&M manual is a treatment system's primary reference book. It is
essential that desired information be easily located. A user guide should
supplement the table of contents and should explain the manual's organi-
zation and its intended use for personnel.
To ensure efficient and economical municipal wastewater treatment system
operation, the responsibilities of both the operational personnel and the
system's management must be clearly defined. The problems confronting
each group must be identified by both parties.
The process-type description should be of an introductory nature and
limited to two pages in the manual. Detailed descriptions of unit opera-
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tions and processes are found in the description, operation, and control
section of the manual. Detailed design criteria should be tabulated in
the manual's appendix. A suggested format for this introductory
description would be to categorize the treatment system by collection
system, pretreatment, primary treatment, secondary treatment, advanced
treatment, disinfection, and sludge handling. Ail units within each
category should be briefly described.
A flow pattern should be in the introduction and should complement the
plant description. It is not intended to illustrate all possible alternate
flow paths in the system. Detailed flow diagrams and hydraulic profiles
should be included in the engineering drawings of the facility.
The introduction of the O&M manual should include a:
a. Manual user guide
b. List of operator responsibilities
c. List of management responsibilities
d. List of available training
e. List of recommended general publications
f. List of specific publications furnished to the facility
g. Brief description of the general plant type
h. Basic flow diagram
2. Permits and Standards:
Personnel in responsible positions within a treatment system may not be
aware that their facility is operating under a federal and/or state dis-
charge permit. The facility's O&M manual is a convenient and practical
location to maintain a copy of this permit with a discussion of the permit
requirements. If operating personnel are aware of permit requirements,
the possibility of permit violations occurring can be reduced.
The importance of having ali treatment system personnel informed of the
reporting procedures for spills of raw or inadequately treated wastewater
cannot be overemphasized, Prompt reporting ensures spill cleanup and
monitoring assistance can be dispatched to help minimize health hazards
and environmental damage. Penalties for negligence in reporting these
conditions are usually severe and could cause negative publicity for the
treatment system.
Treatment system personnel often are not aware that a classification sys-
tem exists for the body of water receiving their facility's treated
effluent. Personnel should recognize the intended use of the receiving
stream and the importance of maintaining a high performance level at the
facility. The plant personnel should be able to relate their receiving
stream's classification to the state's overall classification system.
The permits and standards section includes"
a. A general discussion of plant treatment requirements and efflu-
ent limitations
b. A list of the permits affecting the facility
c. Permit numbers and renewal dates
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d. The summary of permit requirements
e. A discussion of the reporting procedure for spills
f. A discussion of the water quality standards for the receiving
stream
Description, Operation, and Control of Project Facilities:
This section is the key element in the O&M manual because operating
personnel can locate detailed descriptions of the unit operations and pro-
cesses within their systems. Decisions made during plant start-up or
when units are returned to service will be based on the information con-
tained in this section. The flexibility designed into the treatment system
is outlined and proves invaluable in correcting problems arising within
the system.
This section should assist the operator in interpreting the construction
drawings, the purpose and functions of the treatment plant, and the
engineer's concept of operation and control of the wastewater treatment
processes. Photographs and/or schematic diagrams are included to sup-
plement the verbal description of routine, alternate, and emergency
operations.
The following items should be discussed in this section for each unit
process:
a. A genera! unit process description, function statement, and flow
routing through the unit process and design efficiency
b. A listing of the major components and mechanical equipment
c. A discussion of relationship to adjacent units which includes the
types and functions as they relate to the unit or process being
considered
d. Methods of control including manual, automatic, physical, chemical,
analytical, biological, and laboratory control measures
e. A discussion of common operating problems and controls explaining
potential problems that are peculiar to the facility
f. Start-up procedures including inspection and adjustment of all
equipment prior to start-up and outlines of the steps for placing
the unit process in operation and information on special monitoring
and controlling of the unit process until treatment objectives are
met
g. Emergency shutdown procedures
h. The normal operation mode describing valve and gate positions,
wastewater loadings, pump settings, speeds of rotating mechanical
equipment, and process control variables
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i. Alternate operational modes
j. Emergency operations and failsafe features including no bypass,
peak flow capacities, standby power, and overload alarms
4. Personnel:
If a well-designed, well-constructed treatment facility does not have
enough qualified personnel to operate the process, it cannot operate to
its full capacity.
Up-to-date training for operators and maintenance personnel is necessary
for the proper functioning of the wastewater treatment facility. Proper
functioning protects the huge investment in plant equipment from damage
or deterioration and improves the quality of the effluent.
EPA has developed three manuals ("Estimating Staffing for Municipal
Wastewater Treatment Facilities," Contract No. 68-01; "Estimating Costs
and Manpower Requirements for Conventional Wastewater Treatment
Facilities," Contract No. 14-12-462; and "Estimating Laboratory Needs for
Municipal Wastewater Treatment Facilities," Contract No. 68-01-0328) to
provide assistance in estimating facility personnel requirements. The
personnel section of the O&M manual includes:
a. A staffing and training plan to adequately prepare manpower
recommendations, and a task analysis of each job within the treat-
ment system. The staff requirements should be stated outlining
individual areas such as supervision, administration, operation, and
maintenance. If minimum staffing requirements have been estab-
lished by the state agency for various size treatment facilities, the
applicable requirement should be cited. Any state and federal
training programs available at or near the treatment plant should be
included.
b. Qualifications for all positions with job descriptions of each.
c. Details of state certification program if applicable, including a
reference to the rules and regulations of the state certification
board as a supplement to the O&M manual.
5. Laboratory Testing and Process Control:
The treatment system laboratory testing program provides the basis for
process control and produces a record of procedures for operation of the
treatment facilities. This information informs the operating personnel of
plant efficiencies and helps analyze present problems and predict future
problems. Laboratory test results are evaluated by governing and/or
regulatory agencies as a record of plant performance. It is essential
that a treatment system's laboratory testing program produce complete
and accurate results.
To provide detailed information on laboratory equipment and staffing,
EPA has developed a manual entitled "Estimating Laboratory Needs for
Municipal Wastewater Treatment Facilities," Contract No. 68-0328, and
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published guidelines establishing approved test procedures for the analy-
sis of pollutants in the Federal Register, December 1, 1976. The labora-
tory testing section includes:
a. A discussion of the sampling and testing program adapted to the
laboratory staff capabilities of the facility under consideration. The
sampling and testing program should include:
(1) Sampling procedures and their frequency for the various lab-
oratory tests.
(2) Tests to be performed with a brief description for performing
each test may be located in the reference laboratory document.
(3) Definitions of important terms, such as grab sampling versus
composite sampling.
(4) A suggested schedule for performing various laboratory tests.
The EPA manual entitled "Procedures for Evaluation Perfor-
mance of Wastewater Treatment Plants," Contract No. 68-01-
0107, contains a minimum process testing guide.
b. A detailed description of each test in controlling and/or monitoring
specific treatment units, including expected test result ranges.
c. Samples of the recommended laboratory worksheets including a
detailed discussion of the laboratory records.
d. A list of laboratory reference materials.
e. An inventory of laboratory equipment, supplies, and chemicals.
6. Records:
An important factor in any efficient wastewater treatment system is the
maintenance of accurate operational and financial records. A record of
past operational performances helps identify trends in any process.
Operating cost records are essential to prepare accurate budgets. Accu-
rate records permit plant operating personnel and management to main-
tain control of their facility.
The following are principal types of records:
a. Facility construction records list construction mishaps which could
affect later operation.
b. A daily operating log bound in notebooks to prevent the destruction
or alteration of the important records. The daily summary forms a
basic data source for each day's entry on the monthly operating
report.
c. State's required monthly report as it applies to the specific treat-
ment system. (Sample forms should be provided in this section or
in the manual's appendix.)
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d. Annual reports, usually prepared by the treatment plant superin-
tendent, are divided into two parts, a Management Data Section and
an Operation Data Section.
e. A suggested operating cost breakdown for the treatment system and
a record system for monitoring this cost. The major categories of
operating costs are labor, utilities, chemicals, and supplies.
(Labor is divided into operation, administration, and maintenance.
Utilities include electricity, fuel oil, telephone, gas, and potable
water. Chemicals are limited to those used in the treatment pro-
cesses. Supplies include laboratory chemicals, cleaning materials,
maintenance supplies, and other expandable items.)
f. Personnel records procedures reflect items such as training of
individuals and employee turnover rate.
g. A system for maintaining a record of emergency conditions affecting
the treatment facility records, bypass reports, and records of
deteriorated effluent conditions.
h. NPDES reports
Other records such as laboratory maintenance and safety may be includ-
ed, but detailed descriptions of these records should be provided in the
specific sections of the O&M manual.
7. Maintenance Management Program:
The plant management's responsibility is to produce an acceptable efflu-
ent at the lowest unit cost and at the highest quality possible. The
O&M manual should encourage a sound maintenance program by discus-
sing the flexibility and limitations of the maintenance system. For addi-
tional assistance, the EPA has a manual entitled "Maintenance Management
Systems for Municipal Wastewater Facilities," Contract No. 68-01-0341.
The maintenance section of the O&M manual includes the following basic
features:
a. Equipment record system containing the following information for
each piece of equipment:
(1) Description and identifying number with location in plant.
(Each item of equipment requiring maintenance should be
assigned a number for easy identification and to help receive
proper attention.)
(2) Supplier with address, representative, phone number, date of
purchase, purchase price, and warranty provisions
(3) Size, model, type, and serial number
(4) Electrical and/or mechanical data
(5) Spare parts in stock and the procedure for ordering spare
parts or replacements
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(6) Preventive maintenance procedures and their frequency. (The
manufacturer's catalog may be referenced, but should be sup-
plemented with detailed maintenance guidelines specific to the
applications.)
(7) Corrective maintenance requirements
(8) A system to compile expenses for future use in budget devel-
opment. A catalog should be prepared that lists descriptions,
locations, and numbers of equipment plus a preventive mainte-
nance record and nameplate data card file system. This
system may be one card or a number of cards for equipment,
and possibly a combination of cards and data maintained on a
computer for larger plants.
b. Miscellaneous maintenance records of preventive and corrective
maintenance performed on nonequipment items including work des-
cription, manhours, cost, and date. Breakdown reports should be
prepared when major problems are encountered.
c. Planning and scheduling involving time, personnel, equipment, and
available money. Provisions should be made to allow time in the
preventive maintenance schedule for such things as a lubrication
schedule and housekeeping to perform corrective maintenance. A
schedule chart with priorities of subjects, personnel, and time is a
convenient aid to reduce unnecessary work. Maintenance duties
should be scheduled to take advantage of good weather, low load or
flow periods, and other variable conditions beyond the control of
the operating staff. Critical equipment should be given maintenance
planning priority.
d. Storeroom and inventory system consisting of a central storeroom
for spare parts, equipment, and supplies which should be listed in
a central catalog with assigned numbers. A purchase order system
should also be established.
e. Special tool list and toolroom control providing recommendations on
toolroom procedures, the use of tool boards, and maintenance skills
required for all special tools. Tools should be stored in their area
of use.
f. Maintenance personnel staffing requirements referring to the
personnel chapter of the manual which provides job titles, job
descriptions, and qualifications for maintenance personnel. Any
general or specific information and limitations regarding maintenance
personnel should be included.
g. System for cost accounting and budgeting guidelines for the deter-
mination of maintenance cost and development of maintenance bud-
gets for eventual incorporation into the plant's total operation and
maintenance budget. A filing system should be established to main-
tain a record of expenses.
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h. Recommended list of outside contract maintenance tasks and firms
considering plant size, complexity of equipment, and maintenance
personnel qualifications.
8. Emergency Operating and Response Plan:
Emergency conditions can be imposed on a treatment system by natural
disasters, strikes, civil disorders, and equipment failures. Therefore
planning is essential to ensure continued effective operation during
emergencies. An emergency operating and response program is required
for each grant assisted plant in accordance with 40 CFR 35.935-12(b)(2).
This program should be outlined in the corresponding chapter of the
O&M manual. The objectives of this program are to:
a. Eliminate or minimize adverse effects from emergency situations
affecting the treatment system
b. Develop procedures for properly responding to emergencies
c. Provide instruction for system personnel to identify their responsi-
bilities during emergency situations
d. Provide inventories of available emergency equipment and outline
existing mutual aid agreements and contracts with outside organiza-
tions for specialized assistance
EPA has developed two manuals, "Emergency Operating Procedures for
Municipal Wastewater Treatment Facilities," and "Emergency Response
Programs for Municipal Wastewater Treatment Facilities, State-Local
Aspects" under Contract No. 68-01-0341, to assist in the preparation of
local emergency plans.
The following basic features of this program outlined in the O&M manual
are:
a. Vulnerability analysis which is an estimation of the degree to which
the system will be disrupted compared to the function it must per-
form in an emergency situation. These results of the analysis will
include a list of the most vulnerable components and a discussion of
methods to reduce the treatment system's vulnerability.
b. Mutual aid list of the organization to be considered during emer-
gency
c. Emergency equipment list
d. Records preservation outline of the program for the protection of
essential records, maps, and inventories, including a list of the
documents to be protected
e. List of industrial sources including the industrial contributors to
the municipal treatment system, their location on a collection system
map, the names and phone numbers, their key personnel, and a list
of present potential hazardous spill materials
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f. Police/fire coordination containing a checklist of items to consider
g. Detailed personnel assignments ensuring that all regular and auxili-
ary wastewater treatment system personnel recognize their tasks
and responsibilities during emergencies, including procedures for
occasional emergency response drills
h. Readiness/emergency response center description of the failsafe
alarm system, including high water/power failure and critical equip-
ment alarms, both for the treatment plant site and any remote
pumping stations. A program should be established for placing
emergency standby equipment into service periodically. This sec-
tion designates the area that will serve as the emergency response
center (normally the main building at the facility where the alarm
system is located) and a list of the equipment and staffing require-
ments for this center.
i. Emergency operating plan listing possible emergency conditions and
response plan actions. Process diagrams should describe bypassing
of units during emergencies and locate problem areas when emer-
gencies arise.
j. Spills and bypass reporting requirements and procedures
9. Safety:
The primary purpose of this chapter of the O&M manual is to help pre-
vent personal injury to the treatment system staff. Treatment personnel
should be able to recognize safety hazards and should be protected from
these hazards to the greatest extent possible. Proper first aid training
should be provided in the event an accident does occur.
The safety section of the O&M manual includes a discussion of the follow-
ing items:
a. An emergency phone list including the numbers of several local
physicians, the nearest hospital, police and fire departments, ambu-
lance services, rescue squad, and process chemical suppliers
b. A safety equipment list
c. The following hazards discussing the treatment system (when appli-
cable):
1. Sewer hazards
2. Electrical hazards
3. Mechanical equipment hazards
4. Explosion and fire hazards
5. Bacterial infection
6. Chlorine hazards
7. Oxygen deficiency/gases
8. Laboratory hazards
9. Process chemicals handling
10. Possible toxic waste influent
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d. List of safety references of interest to operating personnel
e. A sample accident report form with the accident reporting require-
ments for the treatment system's insurance company
f. A periodic safety program review
10. Utilities:
The utilities serving a municipal wastewater treatment facility perform a
major role in the proper operation of the facility. Frequent or prolonged
interruptions of service can have significant effects, even on systems
that have standby or alternate service. Identification of the size and
capacities of the Sines serving the facility and contact men within each
utility company is essential for proper response to routine and emer-
gency operations.
The O&M manual should include the names of utility suppliers with a
description of their service. A brief statement on the reliability of each
utility source and coordination during emergencies should be included.
Many wastewater treatment plants have overlapping utilities; for example,
the fuel used for heating the plant's control building may be either fuel
oil, natural gas, or digestor gas. The conditions under which each fuel
source is to be used should be described as follows:
a. Electrical
The voltage of the electrical service adjacent to the facility as well
as the reduced voltage entering the plant should be stated. If
standby power is provided from a second line, this system should
be described. A detailed description of the power source should be
included.
b. Telephone
Many alarm systems used in wastewater treatment operations utilize
telephone lines; therefore, disruptions to telephone service should
be minimized.
c. Natural gas
The cubic feet per hour and the normal operating pressure should
be given for the gas lines servicing the facility.
d. Water
The size of the waterline serving the facility and operating pres-
sure should be stated. If a pressure-reducing valve is used, its
function and location should be explained. Any nonpotable water
lines connected to the potable system using backflow preventer
valves and onsite fire protection water supply should also be dis-
cussed.
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e. Fuel oil
A schedule or method of ensuring adequate fuel supplies in stock
should be outlined including capacities of fuel oil storage facilities
at the treatment plant.
11. Electrical System:
The purpose of this chapter is to provide sufficiently detailed informa-
tion on the treatment facility's electrical system to ensure efficient plant
operation. Complete comprehension of the electrical system by plant
personnel is essential because all operations involve some type of electric
motor to power a pump, sludge collector mechanism, or aeration equip-
ment. The electrical system should be described by a combination of
schematic diagrams, tables, manufacturer's descriptive literature, and
manufacturer's and contractor's detailed shop drawings. These docu-
ments can be filed and indexed with the indexing system described in
the O&M manual. The following basic features of the electrical system
should be included in the O&M manual:
a. A description of the power source including:
(1) Name of electric utility company
(2) Characteristics (voltage, overhead or underground, etc.) of
primary distribution line serving the plant
(3) Description of the main transformer(s) (ownership, voltage,
phase, connection, capacity, type, impedance, taps, etc.) as
well as the physical location
(4) Types, ratings, and settings of protective devices
(5) Value of the maximum available short-circuit current at
point(s) of service from the electric utility company
A properly noted one-line schematic diagram could present most of
the above information with a supplement of the manufacturer's liter-
ature and shop drawings.
b. A description of the power distribution system (using a properly
noted one-line schematic diagram) including:
(1) Service entrance equipment description (location, type of equip-
ment, load capacity, short-circuit interrupting capacity,
calculated short-circuit duty, voltage rating, etc.)
(2) Description of all motor control centers, distribution switchgear
assemblies, panel boards, or other major components of the
electrical system
(3) Tabulations of schedules of the components of the above equip-
ment which indicate the power wiring and the loads fed by
such components
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c. Description of process monitoring arid control instrumentation using
appropriate schedules and tabulations indicating the type of controls
and monitors and the process equipment involved. (Where involved
sequences are present, schematic diagrams should be prepared.)
d. The alternate power source described in the same detail as the pri-
mary power source. If the alternate power system includes any
duplicate power distribution equipment, this equipment should be
described in the same detail as the power distribution system.
12. Appendix:
This section of the O&M manual is used for any additional or supplemen-
tal material not appropriately included in the text of the manual. Certain
appendix items may be too bulky or cumbersome to be bound in the
manual itself. These items should be bound separately or folded and
placed in plastic dividers at the end of the manual. Several of the ap-
pendix subject areas are interdependent and the depth of content of any
is substantially dependent on the content of the others.
The appendix should include the following items unless included else-
where or not appropriate to the project:
a. Schematic including basic flow diagrams, process flow sheets, by-
pass piping diagrams, and hydraulic profiles to explain and illus-
trate treatment plant operation.
b. Methods of preparing valve indices including;
(1) A complete tabulation of principal valves, each numbered sep-
arately and identified as to type, location, and function, with
each appropriately field-tagged with a noncorrosive tag.
(2) A coding system for each type of valve (plug, gate, throt-
tling, etc.) together with a prefix or suffix identifying its
liquid content or process function (raw sludge, return sludge,
etc.) and each valve coded on the construction drawings.
(3) A series of sketches for principal valves or clusters of valves
and adjacent buried piping. This sketch permits immediate
location by giving three lateral measurements to nearby perma-
nent aboveground objects. This usually includes a tabulation
of key characteristics such as size, type, year, direction and
turns to open, depth to top of stem, valve box size and mark-
ing, process control, etc.
c. Sample forms including daily operating logs, NPDES reports, state
monthly operating reports, equipment data cards, maintenance work
orders, and purchase orders for supplies and equipment with in-
structions for completing each form.
d. Process chemicals/source listing all process chemicals needed and
the names and addresses of chemical suppliers. An ordering
schedule should be given to ensure adequate quantities are always
in stock.
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e. Detailed design criteria including capacities, flow rates, loading
rates, detention times, unit dimensions, air requirements, recircu-
lation rates, heat requirements, and chemical requirements for all
unit operations and processes.
f. List of equipment suppliers including names, equipment furnished,
and local representative.
g. Manufacturer's manuals furnished with each piece of equipment and
included in the appendix or bound separately.
h. List of service and parts sources including types of repairs and
equipment parts required by the treatment facility.
i. As-built drawings complete and accurate.
j. Approved shop drawings giving the detailed description of special-
ty items such as clarifier sludge removal mechanisms and anaerobic
digester mixing mechanisms.
k. Dimension prints giving the actual relationship between installed
equipment and adjacent walls and openings.
I. Construction photos giving special attention to underground or
other concealed piping and diversion structures labeled and dated.
m. Warranties and bonds such as copies of equipment warranties, roof
bonds, and the contractor's performance bond.
n. State O&M inspection form if the state is not using EPA Form 7500-5
for O&M inspections.
o. EPA Form 7500-5 assisting operational personnel in familiarizing
themselves with the federal inspection criteria.
p. A copy of the enacted sewer use ordinance enclosed for the opera-
tor's i nf ormation.
q. A copy of the industrial waste ordinance or discussion of other con-
trols available.
r. Pretreatment controls/ordinances if the grantee has a pretreatment
program and ordinance.
s. An outline of the piping color code system that is selected for use
in the treatment system.
t. Protective coating list describing the various types of coatings to
be used throughout the facility and giving a suggested painting
schedule. The manufacturer's trade name and number and color
should be specified.
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u. A submitted sewer maintenance program addressing the following:
1. The timely elimination of all excessive inflow sources origina-
ting from private sources which can be cost-effectively re-
moved .
2. The establishment of a continuing sewer maintenance program
to ensure that the sewer system will not be subject to exces-
sive infiltration/inflow in the future.
Existing sewer maintenance programs should be reviewed for ade-
quacy.
v. Map of collection system and lift stations indicating direction of
flow, manhole locations, line sizes, and lift station capacities.
w. Service agreement.
There may be some overlap in the review criteria for style and
format and content. This is unavoidable because the reviews are
quite similar in nature and usually are conducted at the same time.
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PROBLEMS THAT MAY DEVELOP
IF O&M IS NOT CONSIDERED IN STEP 3
O&M consideration may be overlooked during the construction of a waste-
water plant. Many problems that result from a lack of consideration for O&M
in Steps 1 and 2 will extend into the construction phase. Some of the prob-
lems have already been discussed previously and will not be covered.
However, some O&M problems that may develop are:
1. Lack of accessibility of underground piping
2. Blockage of hoist runways
3. Floors sloping away from drain pipe
4. Lack of or inaccessibility of meters and valves
During construction all underground piping should be clearly located.
Care must be taken to avoid the placement of parking lots, buildings, tanks,
etc., over the laid pipes. Under the guidance of the inspector the contrac-
tors must take steps to ensure that all piping is accessible.
Many traveling hoists have become useless because the I-beam has been
blocked. The various contractors should coordinate their activities to prevent
this problem from developing.
Standing water in many wastewater treatment facilities is a common
problem to the operator. It is also a safety and health problem. Equipment
is subject to flooding, causing operating problems. The contractor must
ensure that all floors drain properly.
In many treatment facilities meters and valves are missing or are not
accessible. This presents a real operating problem. Without any means (or
if it is next to impossible to reach meters and valves) to regulate them, flow
process control is impossible. Without process control plant operation is
impossible.
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APPLICATION STEP 3
REVIEW OPERATION CHECKLIST
CHECKLIST
Does application contain approved plans and
specifications?
Plan of operation
a. Has the preliminary plan of operation been
approved?
b. Has an acceptable architectural-engineering
subagreement or intended method of award been
submitted for preparation of the final plan of
operation?
c. Is the cost of the final plan of operation
separately identified?
d. Is the proposed scope of the final plan of
operation adequately defined?
e. Is the final plan of operation scheduled to
be submitted prior to 50 percent completion
of the construction project? (50 percent
federal grant payment will not be made prior
to approval of the final plan of operation)
Does application form include:
a. Legal authority of applicant to construct,
operate, and maintain, and collect revenues
needed for O&M of the proposed facility?
b. Properly signed assurances Form (Part V
Assurance) by applicant assuring proper
O&M of the facility?
Do proposed contracts and subagreements include:
a. A scope of work sufficient to construct operable
facilities?
b. Completion schedules which are reasonable and
in agreement with plans and specifications and
plans of operation (where applicable)?
YES NO NA
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5. Have the following assurances (in addition to part V YES NO NA
of application form) been included in the application?
a. Sewer use ordinance
b. Operation and maintenance scheduling
c. Sewer system rehabilitation scheduling
d. Institutional agreements
e. User charge system or a development schedule
for its adoption
f. Industrial use ordinance or schedule for
development
g. Pretreatment ordinance or schedule for
development
h. Industrial cost recovery system or a
development schedule for its adoption
6. Has applicant addressed O&M manual requirement?
a. Is preparation cost separately identified?
b. What is the O&M manual preparation cost?
c. Is completion schedule included?
7. Does estimated O&M budget appear adequate?
a. What are the:
1. Annual O&M costs $
2. Annual O&M revenues $
b. Are these cost and revenue estimates realistic?
8. Does the staffing and training plan appear to be
adequate?
a. Staffing comment
b. Training comment
c. Staff salaries comment
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d. Training funding comment
9. Does the application include provisions for start-up
services?
a. Has an acceptable subagreement (consulting
engineer and/or equipment, suppliers) or
intended method of award been submitted for
start-up services?
b. Does the start-up proposal include:
1. Pre- and poststart-up personnel training?
2. Fine tuning to optimize process control?
3. Laboratory procedures?
4. Maintenance management system?
5. Records management system?
6. O&M manual updating?
c. For each of the above, does the approval
include:
1. Objectives statement?
2. Schedule for completion?
3. Estimated cost?
4. Contractor/consultant (personnel who
are actually going to perform the start-
up services) qualifications statement?
d. Is the total start-up services proposal cost
presented as a separate line item in the Step 3
application?
e. Are start-up services to be provided by the
grantee's design engineer or by a designated
agent?
f. Estimated time frame for start-up services:
1. man-days
2. months
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g. Estimated cost of start-up services:$_
Recommendation of Step 3 Grant Award
Signed:
Date:
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PRECONSTRUCTION CONFERENCE
OPERATION CONSIDERATIONS FOR DISCUSSION
CHECKLIST
D
YES NO NA
1. Was compliance with state and local law and
ordinances discussed?
2. Has a preliminary plan of operation been approved?
3. Have start-up service provisions been approved?
4. Has a completion schedule for the following been
submitted:
a. Final plan of operation
b. Draft of O&M manual by 50 percent payment
c. Final O&M manual by 90 percent payment
d. Staffing and training
1. Hiring of chief operator by 50 percent
2. Training program developed and implemen-
ted prior to start-up
5. Have requirements for the submission of the following
been discussed:
a. A user charge system
b. Industrial cost recovery system
c. Sewer use ordinance
6. Were the requirements for adequate engineering
supervision and inspection during construction
discussed? (40 CFR 35.935-8)
7. Have construction schedules/procedures been
established to avoid raw sewage bypassing and other
existing facility treatment disruptions?
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YES NO
NA
8. Have procedures been provided to protect and
maintain equipment in storage and in place during
construction, prior to plant start-up?
9. Have the influent characteristics upon which plans
and specifications are based been confirmed through
sampling and analysis by 50 percent completion of
construction?
10. Was applicant informed that onsite inspections of
construction activities will be held?
a. Will an interim inspection be held?
b. Will a final inspection be held?
c.
Other inspections that inspectors deem
necessary may be held.
11
Were changes in plans and specifications during
construction approved by state and EPA prior to
execution discussed?
12. Was grantee informed of its responsibilities under
40 CFR 35.935-1?
Signed
Date
NOTE: If a preconstruction conference is not held, mail this list to the grantee
with a Step 3 grant offer letter.
The preconstruction conference should be a requirement prior to Step 3.
The preapplication and predesign conference materials should be reviewed
again.
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OPERATION AND MAINTENANCE MANUAL
QUALITY EVALUATION REPORT
1. During the review for quality evaluation the reviewer shall make com-
ments on the following:
a. Language:
b. Adaption:
Signed:
Date:
c. Sections:
d. Materials for Inclusion:
e. Scope of Manual:
f. Updating the Manual:
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0&M MANUAL REVIEW OPERATION CHECKLIST
(For Preliminary and Final O&M Manual)
CHECKLIST
D
YES NO NA
1. For Step 3 grants, was draft submitted by
50 percent payment point?
2. For Step 3 grants, will final O&M manual be
approved by 90 percent payment point?
3. For Step 3 grants, will O&M manual be updated
under start-up subagreement/contract?
4. Is draft/final O&M manual clearly and simply
written?
5. Does draft/final O&M manual incorporate (at no
or nominal cost to grantee) sections from EPA
technical manuals and other available reference?
6. Is draft/final O&M manual in looseleaf form,
organized in a logical sequence to encourage use,
refining, and updating?
7. Detailed review of the O&M manual.
Note: This section is presented in an outline form
as an aid to the reviewer.
Does the O&M manual contain the following:
I. AN INTRODUCTION AND MANUAL USER GUIDE
A. Operation and Managerial Responsibility
i. Operator responsibilities defined
2. Manager responsibilities defined
3. List of available training
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YES NO NA
4. List of recommended publications
5. List of publications furnished to
the facility
B. Process Type Description
1. Type of treatment process
a. Brief description of major
process
b. Brief description of individual
units
2. Flow pattern with diagram
PERMITS AND STANDARDS
A. Treatment Requirements/Effluent Limitations
B. List of Permits Affecting Facility (including
NPDES, Corps of Engineers Section 10/404,
etc.)
1. Permit number and renewal date
2. Permit requirements/regulations of
permitting agency
3. Reporting procedure for spills
C. State Water Quality Standard For Receiving
Stream
DESCRIPTION, OPERATION, AND CONTROL
OF PROJECT FACILITIES
A. For Each Unit Process, General Coverage
of the Following:
1. Description, function, flow routing,
and design efficiency
2. Listing of major components and
mechanical equipment
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YES NO NA
3. Relationship to adjacent units
4. Methods of control
5. Discussion of common operating
problems and control
6. Start-up procedures
7. Emergency shutdown procedures
B. For Each Unit Process, Specific Coverage
of the Following:
1. Normal operation (valve positions,
sludge depths, etc.)
2. Alternate operation modes
3. Emergency operations/failsafe features
IV. PERSONNEL
A. Staffing and Training Plan
1. Supervision
2. Administration
3. Operation
4. Maintenance
5. Total personnel
6. Annual training
7. Laboratory training needs
B. Qualifications
1. Training
2. Skills required
3. Experience
4. Certification required
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YES NO NA
C. Certification
1. Copy state rules and regulations
2. Certification requirements of facility
V. LABORATORY TESTING AND PROCESS CONTROL
A. Outline of Sampling and Testing Program
Discussion of Purpose
B. Discussion of Laboratory Results, Expected
Ranges and Process Control Adjustments
from Test Results
C. Provision of Sample Laboratory Worksheets,
Instructions, and Test Results Forms
D. Recommended List of Laboratory References
E. Laboratory Equipment, Supplies, and
Chemicals Inventory
F. Operating Cost Recordkeeping System
Recommendations
G. Personnel Record System Recommendations
H. Emergency Conditions, Bypass Reports,
Permit Violations, etc.
I. Maintenance and Laboratory, If Not
Provided Elsewhere
VI. RECORDS
A. General - Importance of Recordkeeping
B. Facility Construction Records
C. Sample of Daily Operating Log of Process,
Operations, Instructions
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YES NO NA
D. Sample of Monthly Operating Report to
State Agency and Instructions
E. Sample of Annual Report Format
F. Operating Cost Recordkeeping System
Recommendations
G. Personnel Record System Recommendations
H. Emergency Conditions, Bypass Reports,
Permit Violations, etc.
I. Maintenance and Laboratory, If Not
Provided Elsewhere
VII. MAINTENANCE
A. Conceptual Description of Maintenance
Program
B. Equipment Record System
1. Equipment numbering system
2. Equipment catalog (configuration list)
3. Maintenance record cards, instruction
4. Nameplate data cards, all major
equipment
5. List of warrantied equipment,
warranty provisions
C. Miscellaneous Maintenance Records
D. Planning and Scheduling
1. Normal preventive maintenance
schedule provided
2. Lubrication schedule and lubricant list
3. Emergency, corrective maintenance
4. Work order system and sample form
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YES NO NA
E. Storeroom and Inventory System
1. Recommended list of spare parts
2. Procedures, stockroom inventory,
sample forms and records
F. Special Tool List and Toolroom Control
G. Maintenance Personnel Staffing Requirements
H. System for Cost Accounting and Budgeting
I. Recommended List of Outside Contract
Maintenance Tasks and Firms
VIII. EMERGENCY OPERATING AND RESPONSE PLAN
A. Objectives
B. Vulnerability Analysis
C. Mutual Aid List
D. Emergency Equipment List
E. Records Preservation
F. List of Industrial Sources (Including
Monitoring and Response System)
G. Police/Fire Coordination
H. Personnel Assignment In Detail
I. Readiness/Emergency Response Center
J. Emergency Operating Plan
IX. SAFETY
A. Importance of Safety Program
B. Content
1. Emergency phone list
2. Safety equipment list
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YES NO NA
3. Sewer hazards
4. Electrical hazards
5. Mechanical equipment hazards
6. Explosion and fire hazards
7. Bacterial infection
8. Chlorine hazards
9. Oxygen deficiency/gases
10. Laboratory hazards
11. Process chemicals handling
12. List of references
C. Periodic Safety Program Review
D. Accident Report Form
X. UTILITIES
A. List of Utility Suppliers
1. Electrical
2. Telephone
3. Natural gas
4. Water
5. Fuel Oil
B. Capacities, Limitations, Responsibility
Coordination
XI. ELECTRICAL SYSTEM
A. Power Source Description
B. Distribution System
C. Control and Monitoring System
D. Emergency Procedures
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YES NO NA
XII. APPENDIX
A. Schematics
B. Valve Indices
C. Sample Forms
D. Process Chemicals/Source
E. Detailed Design Criteria
F. Equipment Suppliers
G. Manufacturer's Manuals
H. Sources; Service and Parts
I. As-Built Drawings
J. Approved Shop Drawings
K. Dimension Prints
L. Construction Photos
M. Warranties and Bonds
N. State O&M Inspection Form
O. EPA Form 7500-5
P. Sewer Use Ordinance
Q. Industrial; Ordinance/Control
R. Pretreatment Controls/Ordinances
S. Piping Color Code
T. Protective Coating List
U. Sewer Maintenance Program
V. Map of Collection System and Lift Stations
W. Recommended References
Comments Attached: Yes No NA
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Implementation Dates and Reminders: Date
1. DOMM review comments sent to grantee
2. DOMM acceptance letter sent to grantee
3. DOMM certification (checklist) to EPA
4. FOMM review comments sent to grantee
5. FOMM approval letter sent to grantee
6. FOMM certification (checklist) to EPA
Reviewer Signature: (DOMM)
Draft O&M Manual
Date:
Reviewer Signature: (FOMM)
Final O&M Manual
Date:
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START-UP
SERVICES
UNIT
5
5-1
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UNIT FIVE
OBJECTIVES
Following the Unit Five presentation, the participant will be able to:
1. Discuss the planning, need, and use of start-up services.
2. Evaluate the training programs outlined in the start-up services
proposal.
3. Determine the qualifications of the start-up service provider.
4. List services thai are grant eligible for funding.
5. Utilize review criteria and checklist in determining start-up proposal
funding eligibility.
5-2
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UNIT FIVE
OUTLINE
I. START-UP SERVICE PROPOSALS 5-4
A. Start-Up Services Planning, Use, and Needs
B. Start-Up Service Training
C- Start-Up Service Provider
D. Start-Up Services Funding and Eligibility
I. START-UP SERVICES REVIEW CRITERIA AND CHECKLIST 5-17
5-3
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START-UP SERVICE PROPOSALS
Start-Up Services Planning, Use, and Needs
The construction grants program provides funding for the planning,
design, and construction of wastewater treatment plants. The primary
function of these wastewater treatment plants is to collect and treat waste-
water to oblain specific conditions arid limitations on the discharged effluent.
The wastewater treatment facility must begin the effective treatment of waste-
water from the first day of operation in order to meet these required condi-
tions and limitations. The key to providing effective wastewater treatment is
successful plant start-up.
Start-up does not just happen. It requires
months of preparation. Step-by-step start-up proce-
<
dures must be developed. All operating and main-
tenance personnel should be hired well in advance (6
months recommended) of start-up. Classroom and
field training on specific plant systems and compo-
nents must be held. O&M procedures must be completed and explained. All
manufacturer's equipment training programs should be completed. The main-
tenance management system must be complete and functional. All of these
must be done to assure an effective plant start-up.
Start-up may be defined as a series of events that lead to a stabilized
routinely controlled unit process or plant. This includes prestart-up prepara-
tion, start-up of primary (if any) and secondary treatment units, chlorination
facilities, laboratory procedures, sludge handling process and units, post-
start-up training, and O&M manual rex/ision and update.
5-4
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Start-up of any wastewater treatment facility is a complex operation. It
requires careful planning, effective coordination, and a detailed preparation
to maximize the treatment plant's efficiency and minimize problems. The
information contained in the start-up proposal should provide operation and
maintenance personnel with the guidelines necessary to inspect and adjust all
equipment prior to start-up. The start-up services should outline all steps
for the placing of treatment units or processes in operation. It should also
provide information on monitoring and controlling of the unit and/or process
until treatment objectives are met. The start-up proposal should also tell
what should be done to continue meeting treatment objectives.
Information contained in a start-up proposal should be tailored to meet
the needs of the specific plant. Proposal for a 1 MGD activated sludge plant
would be different, although similar, to those for a 20 MGD activated sludge
plant. Careful consideration should be given to a start-up service proposal
to ensure that no important activities are overlooked.
Start-up services will help assure that the wastewater treatment facility
achieves operational objectives quickly and effectively. Successful plant
start-up will assure that:
1. Design operational efficiency is achieved as quickly as possible
2. Control and related equipment problems are identified and resolved
3. Onsite instruction to personnel in details of the process and equip-
ment of each particular plant is provided
4. Final revision of the Q&M manual, based upon actual operating
experience, is made
These goals can only be met with a carefully planned and properly imple-
mented start-up service plan.
-------
Adequate consideration of plant start-up is essential to assure subse-
quent plant operation with a minimum of problems and to set the proper
framework for long term, trouble free, efficient plant operation under all
conditions.
In addition to assuring effective plant start-up, these services provide a
very important use. Start-up services are needed because they pull the
entire O&M program together before the closing out of Step 3 grants. Start-
up services will ensure that the plan of operation has been implemented. The
plan of operation identifies specific actions and related completion dates to
assure that the wastewater treatment facility and all associated personnel are
properly prepared for start-up and continued operation. The relationship of
start-up services and the plan of operation is simple. One is a plan, the
other is the tool to implement the plan.
Start-up is also part of the O&M manual. This
provides the means of tying the O&M manual and plan
of operation together. The O&M manual gives the
detailed procedures for start-up. The plan of opera-
tion identifies specific actions and dates for start-up
and continued operation. Start-up services provide
the means for implementing the plan of operation using the information pro-
vided in the O&M manual.
This relationship provides all personnel associated with the O&M program
(engineer, regulatory agency, plant personnel, owners, equipment suppliers,
etc.) a chance to evaluate and correct (if needed) the entire O&M program
for the wastewater treatment facility.
5-6
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Start-up services are the designer's ultimate
challenge. All phases of wastewater treatment must
be brought into focus in a cost-effective and timely
manner. The major objective for plant start-up is to
achieve plant performance objectives quickly and
efficiently. To meet this objective, start-up services,
\ _
must address the performance of the plant staff and the performance of the
plant equipment.
Other issues that interact in achieving plant start-up objectives are a
maintenance management program, plant management records system, labora-
tory support, process tuning, and O&M manuals.
Start-Up Service Training
Start-up training is twofold. First, the plant personnel are provided a
broad knowledge of all processes, equipment, and instrumentation at the
facility. The importance of process interactions and development of sound
judgement and initiative are stressed. Staff training should produce strong
supervisors and a highly qualified staff with a team approach to facility O&M.
Second, the designer can learn from the plant's O&M staff ways to
improve plant design, plans and specifications, start-up procedures, training,
and O&M manual. From the information obtained, the designer will be able to
develop a more effective O&IV1 program.
The most important use of start-up services is
as a training program. Meeting effluent performance
requirements in a cost-effective and timely manner is
the objective of plant start-up. Successfully starting
up any wastewater treatment facility is a major task.
It requires a training program that motivates and
5-7
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draws the full potential from plant personnel, that coordinates plant equip-
ment operation to plant process operation, and that coordinates all other
aspects of plant operation including:
1. Management
2. Maintenance scheduling
3. Laboratory controls
4. Use of O&M manuals
A brief review of the basic start-up elements is needed to understand
the start-up training. These are:
1. Hire personnel
2. Establish the maintenance management system and train personnel in
its use
3. Establish the laboratory procedures and train personnel in their use
4. Establish the records management system and train personnel in its
use
5. Provide prestart-up training in
a. plant operation
b. plant maintenance
c. plant supervision and maintenance
6. Check equipment and instruments
7. Start system with hands-on training
8. Fine tuning of systems and instruments
9. Revise plant O&M manual
10. Prepare first annual report
Each of the elements involves some degree of training because of the working
relationship between plant personnel and start-up service personnel.
5-8
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Much of this training may be carried out by equipment suppliers and
contractors. The quality of this training, however, is dependent upon the
requirements contained in the plans and specifications. The design engineer
must be specific in the type of service wanted. The specifications should
require that the equipment supplier and/or contractor provide:
1. Mechanical start-up services
2. Process start-up services
3. Training of plant personnel
To obtain these services the designer should state what is required in terms
of personnel and time. This training can go a long way in making the waste-
water treatment facility function properly.
There are basically three elements to any effective training program:
1. Preparation
2. Delivery
3. Followup
Preparation should begin early in the design phase. At this time,
staffing estimates, start-up operating concepts, and construction scheduling
are finalized. The preliminary plan of operation has been prepared, outlining
start-up and training activities. A draft of the O&M manual should be pre-
pared at this time as well.
During the construction phase, the final O&M manual and plan of opera-
tion are begun. A start-up training schedule must be coordinated with the
O&M manual. The trend in start-ups has been towards a phased approach.
As construction is completed, the start-up training is begun. So the O&M
manual author must develop those sections needed for consideration with
start-up training.
5-9
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During program preparation the trainer should meet with the plant staff.
At this meeting the trainer will develop basic training program outlines. The
trainer must become familiar with plant personnel and their backgrounds.
This will enable the trainer to target the training program to meet their
needs. The trainer will also determine what type or style of delivery is
needed. The trainer may, at this time, develop the plant's reference library
and order the required items. As these training programs are developed and
refined, they will become part of the plant's O&M manual.
The delivery of the program is very important.
The delivery must be in a manner that is easily
understood by the participants. The instructor must
have both training and technical expertise. The
presentation should be short and informal and the
participants should be involved and interact as much
as possible. Although the training is on site, the delivery should be a
combination of classroom and hands-on training. A pure lecture approach to
training is not very effective.
After the training program has been delivered the start-up service
trainer must implement a followup program. The importance of a followup
program is almost never considered. Start-up services must provide more
than just well-trained staff and efficient operation. The turnover rate at
most wastewater plants is very high. The shortage of well-trained, qualifed
operating personnel in the wastewater field is becoming worse. To help the
plant deal with this problem, the start-up service provider must establish a
followup system to provide the plant with an ongoing training program for
new personnel. A training officer should be appointed to accept the respon-
sibility for the training program. There should be some type of reward or
5-10
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incentive for new and old employees to increase their skills and knowledge of
treating wastewater.
Start-up training is customized training provided by a consultant. To
be effective, time and effort must be spent in preparation. The delivery
must be appropriate to fit the needs of the plant and its staff. Training
should be evaluated to determine if the expected learning outcomes were
achieved. A followup program is a must to provide ongoing plant training.
The benefits of a good start-up are tremendous. The plant that has a poor
start-up program will pay the price for many years to come.
Start-Up Service Provider
Who should perform the start-up services for the plant? Program
Requirements Memorandum (PRM 77-2) states: "To be grant eligible, the
services must be rendered by the design engineer or other identified by the
design engineer." This places the design engineer in the driver's seat to
provide or direct start-up services. The design engineer does appear to be
the most logical person to provide site-specific start-up services. The en-
gineer designed the plant, is instrumental in O&M manual development and
plan of operation, and knows more about the plant and its performance
objectives than anyone. The knowledge of the design engineer is very impor-
tant to plant start-up. However, this is not enough. Since start-up
services are a training function of the provider, it is very important that the
engineer have training expertise equal to or exceeding his/her technical
expertise. The engineer's knowledge of the plant and its performance
objectives are of little use to others if it cannot be successfully communicated
to them.
The requirement found in PRM 77-2 seems logical, at first glance, to
provide proper and effective start-up services. Further investigation reveals
5-11
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flaws in PRM 77-2. It does not assure that proper and effective start-up
services are provided. PRM 77-2 does not address the "qualifications" needed
to develop, deliver, and follow up an effective start-up program. Having
qualified personnel to coordinate start-up services is very critical. The
provider must have the expertise to utilize the various tools of the training
profession and must be able to respond to a variety of attitudes and educa-
tional conditions found at the treatment facility. The provider must have the
resources to provide special manpower or technical support as needed.
In summation, effective start-up depends upon both technical knowledge
and the ability to communicate. Without both, the goal of meeting the objec-
tive effluent performance requirements in a cost-effective and timely manner
will not be reached.
Start-Up Services Funding and Eligibility
Construction Grants Program Requirements Memorandum (PRM 77-2)
identifies specific services rendered during the 5tart-up period of a waste-
water treatment facility that are eligible for grant funding. These services
will help assure that wastewater treatment facilities achieve operational objec-
tives rapidly and effectively.
EPA, in response to the need for more emphasis on the operation and
maintenance of federally funded wastewater treatment facilities, has deter-
mined that the costs of certain sta^t-up services are eligible for funding.
Such start-up services mu<;t assure that:
1. Design operation efficiency is achieved quickly
2. Process control and equipment problems are identified and resolved
3. Onsite instruction of personnel on the process and equipment is
provided
4. The O&M manual is revised and updated
5-12
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To be eligible for landing, the start-up services must meet the following
terms and conditions:
1. Pre- and poststart-up personnel training--!.e., onsite training
given plant operation and maintenance personnel on the operation
and control of the specific treatment processes of the facility as
well as specialized training required for the. safe operation and
maintenance of plant equipment. It could also include consultation
on the staffing and training plan before completion of construction.
Such consultalion would be supplemental to the O&M manual and
intended to give plant personnel a clear understanding of individ-
ualized operational and management responsibilities. Grant eligible
training and related consultation are not to be substituted for rou-
tine, entry-level or update operator training, the funding of which
is the responsibility of the grantee.
2. Fine tuning ta optimize process control--!.e., expert operational
assistance for adjustment and fine tuning of the treatment processes
and related equipment functions to optimize performance, safety,
and reliability under actual operating conditions. This should
include the detailing of operational procedures under both normal
and abnormal conditions so as to achieve consistent, reliable, and
efficient peformance from each process component al all times.
3. Laboratory procedures--! .e., onsite training
and instruction to assure that the sampling
and laboratory testing program needed for
satisfactory process control and regulatory
monitoring and reporting are fully under-
stood . Entry-level or update training in basic laboratory testing
-------
and_ jprocedures ':or routine analyses are not grant eligible, although
training in unique testing requirements related to some unusual
unit process equipment may be determined to be grant eligible.
4. Maintenance management system--! .e., start-up services to assure
effective implementation of the maintenance management system
outlined in the facility's O&M manual. Included is training of the
operation and maintenance staff in the details of the maintenance
maneigement system to establish and maintain a preventive mainte-
nance program.
5. Records management system--!.e., services to provide the training
needed to implement a records management system as outlined in the
O&M manual. It will become a major element in the larger and more
complex plants that require a refined system to adequately handle
records related to process control, effluent quality monitoring and
reporting requirements, inventories for chemicals, supplies, and
spare parts, etc
6. Revise O&M manual--!.e., revising the O&M manual based upon
actual operating experience obtained during the start-up period. It
is not intended to replace the present requirements for drafting and
finalizing the O&M manual before plant start-up, but does recognize
that some aspects of plant operation and process control can be
documented more fully after a period of actual plant operation.
In addition, grant eligible start-up services will average 90 man-days for
most treatment plants. For large or complex plants, however, grant eligible
start-up services may range up to 300 man-days. Start-up services shall be
completed within a period of twelve months. In addition to grant eligible
start-up services, grantees, in most cases, should be encouraged to negotiate
5-14
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separate agreements for technical and training services to identify and solve
operational problems beyond the initial start-up period. However, only that
period of time which conforms with guidance provided herein will be eligible
for grant assistance.
Grant eligible start-up services are limited to those items described
above. (Other services proposed for grant eligiblity will be considered only
on a case-by-case basis by the regional administrator.) The extent of such
services will depend on the size and complexity of the facility and the capa-
bilities of existing or new operational and management staff. In many cases,
services to address the potential needs above may be coupled with other
related services. To be grant eligible, the services must be rendered by
the design engineer or others identified by the design engineer. Services
that do not meet these assurances, terms, and/or conditions are not grant
fundable.
Start-up service participation is optional. If grant participation is
desired, then the following must be done:
1. The design engineer must submit a proposal. Proposals for start-
up services will be submitted with the Step 3 grant application.
2. The design engineer shall provide all services or certify a subcon-
tractor who is qualified to provide the service.
3. The start-up services should be under the supervision of a certi-
fied operator at the level of certification which is required of the
operator of that treatment facility.
4. Start-up service proposals will be approved and certified by the
state agency and/or EPA tor approval.
5. Proposal will contain service requested, course curriculum or train-
ing outline, persons providing services and their operational and
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training qualifications, and the number of days needed to accom-
plish each task.
6. Proposal will contain a cost breakdown of the services requested.
7. Start-up services will be completed within a period not to exceed 12
months from the time the plant commences actual operation treating
domestic sewage. If prestart-up personnel training is required, the
period, not to exceed 12 months, will commence at the time this
training begins.
In summation, start-up services provide the means to achieve the goal of
meeting effluent limitations in a cost-effective and timely manner. Those
services must be tailored to a specific plant and its staff's needs. Personnel
providing the start-up service must have:
1. Technical expertise
2. Training expertise
3. An operations background
4. Resources to call upon for additional manpower or technical support
Plant performance will suffer greatly if the grantee does not participate in
start-up services. The long term benefits of participation in a good start-up
program far outweigh any additional effort and costs the grantee may incur.
The lack of a good start-up program will cost the grantee for many years to
come.
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START-UP SERVICES REVIEW CRITERIA AND CHECKLIST
Using the review criteria and the Start-Up Services Review Operation
Checklist contained in this manual (page 5-20), the reviewer will be able to
ensure that the start-up service proposal contains the following information
and conforms to PRM 77-2.
During the review the reviewer must ensure that the start-up service
proposal contains the following:
1. Prestart-Up and Poststart-up Personnel Training
This includes onsite training given plant operation and maintenance
personnel for specific and specialized treatment processes of the facility.
Consultation for a staffing and training plan before completion of con-
struction may also be considered. However, grant eligible training and
related consultation are not to be a substitute for routine, entry-level or
update operator training, the funding of which is the grantee's responsibility.
2. Fine Tunjng to Optimize Process Control
This means expert operational assistance for
adjustment and fine tuning of the treatment processes
and related equipment functions. Fine tuning must
be based on actual operating conditions and detail the
operational procedures to achieve consistent, reliable,
and efficient performance from each process component at all times. It should
also include operating procedures under both normal and abnormal conditions.
3. Laboratory Procedures
This includes onsite instruction to assure that the sampling and labora-
tory testing program for regulatory monitoring and reporting are understood.
Training for routine analysis is not grant eligible, but training in unique
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testing requirements related to some unusual unit process or process equip-
ment may be determined eligible.
4. Maintenance Management System
Training of the operation and maintenance staff in details of the mainte-
nance management system to establish and maintain a preventive maintenance
program is to be included.
5. Records Management System
Services to provide the training needed to implement a records manage-
ment system are to be included. The records to be maintained are those
related to process control, effluent quality monitoring and reporting require-
ments, inventories for chemicals, supplies, spare parts, etc.
6. Revision of Q&M Manual
The O&M manual is to be revised based upon actual operating experience
obtained during the start-up period.
The proposal must contain a completion schedule indicating that the
services will be completed within 12 months from start-up or date services
began. It should also include the number of man-days required to accomplish
the proposed start-up services. Grant eligible start-up services will normally
average 90 man-days for most treatment facilities. Larger or more complex
plants may require more. The total number of allowable man-days may be
increased to 300.
As stated earlier, a start-up service proposal must be presented as a
separate line item. This, is necessary to judge the cost-effectiveness of the
proposed services.
The proposal must include who is to perform the start-up services and
that person's qualifications. These should include:
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a. past experience
b. past training programs
c. technical background
d. training background
e. operations background
f. resources to do the required tasks.
The start-up services proposal must assure that:
a. design operational efficiency will be achieved in a cost-effective and
timely manner
b. process control problems and related equipment problems are iden-
tified and corrected
c. onsite training of personnel in the details of process and equipment
operation will be provided
d. O&M manual will be updated based upon actual O&M experience
After determining if the start-up services meet all requirements, the
reviewing agency may then approve the proposal. A letter of approval is
sent to the grantee stating that the start-up services proposal has been
accepted and approved.
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START-UP SERVICES
OPERATION REVIEW CHECKLIST
3. Do proposed start-up services include:
a. Pre- and poststart-up personnel training;
including onsite training?
b. Fine tuning to optimize process control?
c. Laboratory management training?
d. Maintenance management training?
e. Records management training?
f. O&M manual revision?
4. a. Will start-up services be accomplished within
12 months after start-up?
b. How many man-days are required to accomplish
proposed start-up services?
days.
5. Is start-up presented as a separate line item?
6. Is the start-up service provider qualified?
7. Do proposed start-up services assure:
a. Design operational efficiency will be achieved
quickly?
b. Process control problems and related equipment
problems are identified and resolved?
c. Onsite instructions to personnel in the details
of process and equipment of plant will be
provided?
CHECKLIST
a
YES NO NA
1. Did the Step 2 grant application include a
commitment to prepare start-up provisions?
2. Did the Step 3 grant application include clearly
defined start-up provisions in a cohesive proposal?
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d. That revisions to O&M manual will be based
upon actual operating experience?
8. Summary_
Signed
Date
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O&M CONCERNS
IN
INSPECTIONS
UNIT
6
6-1
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UNIT SIX
OBJECTIVES
Following the Unit Six presentation, the participant will be able to:
1. Identify and discuss the three basic types of inspections:
a. Construction (onsite)
b. O&M concerns
c. O&M evaluation
2. Discuss the Army Corps of Engineers' role in inspections.
3. Discuss the kinds of construction inspections and list what is required
by each.
4. Conduct an O&M considerations inspection to ensure that all of the O&M
requirements in the construction grants process are being met or have
been met by the grantee.
5. Utilize the interim and final construction operation review checklist when
conducting an operation review.
6. Explain the enforcement procedures that may be used when it has been
determined that the grantee has failed to comply with all applicable laws,
rules, and regulations and all other attempts to resolve the problem(s)
have failed.
7. Discuss the need to develop an inspection information feedback system.
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UNIT 6
OUTLINE
I. INSPECTIONS 6-4
A. Types of Inspections
B. Corps of Engineers' Role in Inspections
C. Construction Inspections
D. O&M Considerations Inspections
E. Enforcement Remedies
II. EVALUATION OF O&M 6-10
III. INSPECTION FEEDBACK 6-13
A. Introduction
B. Importance
C. Purpose
D. Sources of Feedback
E. Incorporating Feedback into the Construction Grants Process
IV. INTERIM CONSTRUCTION INSPECTION REVIEW OPERATION
CHECKLIST 6-15
V. FINAL CONSTRUCTION INSPECTION REVIEW OPERATION
CHECKLIST 6-17
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INSPECTIONS
Types of Inspections
There are three basic types of inspections.
They are the:
1. Construction Inspection (onsite)
2. O&M Program Considerations Inspection
3. Evaluation of Operation and Maintenance of
Wastewater Treatment Plants
Each inspection is equally important to proper plant performance.
Corps of Engineers' Role in Inspections
In many states the Corps of Engineers conducts inspections. These
inspections may be:
1. A review of plans and specifications for constructability
2. Onsite inspections during construction
The extent of the Corps of Engineers' responsibilities during the inspection
process depends upon the agreements between the state and/or EPA and the
Corps of Engineers.
Construction Inspections
Construction inspection (onsite) is based upon a time frame and can be
divided into two kinds:
1. Interim
2. Final
The frequency of interim inspections depends upon the size and complexity of
the project. This inspection may be a continuous one.
The final construction inspection is conducted following completion of
construction.
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The construction inspection processes start on the initial day of con-
struction and end when the owner accepts the facility. Proper inspection
ensures that the facility was built according to all approved grant documents
and that sound construction principles have been followed.
O&M Considerations Inspections
All federally funded treatment works must have a
well planned operation and maintenance program.
Like the construction inspection, the O&M con-
siderations inspection can be based upon a time frame
and is also divided into:
1. An interim inspection
2. A final inspection
The interim inspection is conducted to ensure that all construction grants
O&M requirements are being met by the grantee. The reviewer should use
the Interim Construction Inspection Operation Checklist when conducting the
review. This checklist will aid the reviewer in determining if the grantee has
complied or is complying with the O&M requirements of the construction
grants process. During the interim construction operation review, the
inspector will determine that:
1. The preliminary plan of operation has been approved
2. Proof of completion of the final plan of operation has been submitted
3. The draft O&M manual has been submitted and approved
4. Proof of completion of the final O&M manual has been submitted
5. Start-up services have been approved
6. Provision for start-up is underway
7. The grantee has hired the operational staff and is providing train-
ing, as appropriate
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8. The grantee is preparing a user charge and an industrial cost
recovery system
9. The grantee is making satisfactory progress toward completion of
service agreements
10. A procedure exists to call deficiencies (including design oversights)
to the attention of the authorized representative
11. The grantee is providing wastewater treatment capability during
construction
12. Equipment delivered to the site is being properly protected and
stored
13. Influent characteristics have been confirmed
14. Design errors in plans and specifications have been corrected
15. Proof of completion of tasks specified in the preliminary or final
plan of operation has been shown
The inspector should make notes on the progress
of the grantee's compliance with O&M requirements.
Deficiency areas should be corrected prior to the final
inspection. The grantee should be reminded of
payment schedules based upon compliance with O&M
program concerns. An inspection conference can be
helpful in reminding the grantee that compliance with O&M requirements is
important not only for grant payments but for efficient plant performance in
years to come.
After meeting all of the final inspection requirements, as construction
permits, the project is ready for the final O&M considerations inspection.
The inspector must ensure that all interim requirements are met. Additional
requirements include:
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1. Approval of the O&M manual
2. Approval of the final plan of operation
3. Completion of all elements of the plan of operation (see Plan of
Operation Checklist, page 3-52)
4. Evaluation and correction of the grantee's O&M program as needed
(the reviewer can refer to the checklist used during the various
operational reviews)
5. Establishment of routine maintenance management
6, Availability of accounting records for audits
7. Completion of user charge system, sewer use ordinance, and service
agreements if not already approved
8. Pretreatment of waste by industrial dischargers as required
The final inspection provides an opportunity for the reviewer to ensure that
all O&M program requirements have been complied with. Final payment must
be withheld until the grantee has complied with all O&M program concerns in
an approvabie manner. The O&M program enacted by the grantee will be
evaluated; any weakness must then be corrected and reviewed again. Getting
the plant started with an efficient O&M program will improve overall plant
performance.
In reviewing the grantee's O&M program, the reviewer must utilize the
PRM's, CFR's, and all previously discussed guidelines. An O&M program that
ensures good plant operation and maintenance depends upon the reviewer, the
design engineer, the owner, and the operator. If they all work together,
plant O&M wiii be greatly improved.
Enforcement Remedies
If it is determined that the grantee has failed or is failing to comply
with all applicable laws, rules, and regulations, the Regional Administrator
6-7
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can impose any or all of the sanctions found in 40 CFR 35.965 (Enforcement).
Any deficiencies noted during the inspection process must be corrected
promptly. Delay in correcting the deficiencies may cause the withholding of
funds as directed by 40 CFR 30.615-3 (Withholding of Funds). This CFR
authorizes the withholding of grant payment where it is determined that a
grantee has failed to comply with project objectives, grant award conditions,
or EPA reporting requirements.
If the withholding of funds does not readily
move the grantee into action then a stop work order
may be issued in accordance with 40 CFR 30.915
(Suspension of Grants-Stop Work Orders). A stop
work order is the first step in grant termination.
The issuance of a stop work order means that there
are serious problems associated with the grant and/or construction of the
wastewater treatment plant (30.915-1, Use of Stop Work Orders).
If problems are not resolved after a stop work order is issued then
steps can be taken to terminate the grant (40 CFR 30.920, Termination of
Grants).
Another option is annulment of the grant rather than termination (40
CFR 30.920-5, Annulment of Grant). The grant can be annulled if the
grantee fails to achieve the project purpose. In this event, monies paid to
the grantee will be refunded to the EPA. In addition, the grantee may be
found nonresponsible and ineligible for future EPA grant awards.
These enforcement procedures apply to both onsite inspections and O&M
considerations inspections. In addition to these procedures, certain grant
payment limitations may apply in the O&M considerations inspections process
(i.e., the 50 percent, 80 percent, 90 percent payment requests) unless
certain O&M requirements are met.
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The deficiencies found during the inspection may be the contractor's
fault. If so, the grantee must enforce the contractual agreement with the
contractor. The grantee generally has certain remedies for enforcement
(depending upon contract terms). If it becomes necessary the grantee may
enlist the aid of EPA in enforcing their contractual agreements (40 CFR
35.910, Contract Enforcement).
It must be noted that the above enforcement remedies will be used only
as a last resort. The use of these remedies must be cleared with the
Regional Administrator or the Assistant General Counsel of Grants.
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EVALUATION OF O&M
This evaluation is extremely important to facility
O&M. It is conducted to determine whether the
wastewater treatment facility is being operated effi-
ciently and effectively in accordance with plant
design.
This evaluation is a state responsibility. According to 40 CFR 35.925-10
Operation and Maintenance Program, and PL 92-500, no grant will be awarded
unless the state water pollution control agency assures the regional adminis-
trator that the state will evaluate the operation and maintenance of each fed-
erally funded treatment works. The states will have an effective operation
and maintenance monitoring program to assure that federally funded treatment
works are operated and maintained according to applicable permit and grant
conditions. This activity shall be clearly identified in the annual state plan
submitted to EPA.
The inspection report (EPA Form 7500-5) shall contain the following as a
minimum:
1. General information including the date of evaluation, plant identifi-
cation and location, name of inspector and title, type of plant and
collection system, and estimated total population served as well as
industrial population equivalents served.
2. Plan loading performance data including average daily flow (MGD);
peak flow rate for wet and dry weather (MGD); percent of daily
industrial flow to plant; date, time, and volume of any wastes
bypassing the plant; summary of laboratory analyses data on raw
waste and final effluent and other significant unit processes.
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3. Information on operating personnel including staff complement and
qualifications of personnel in each job category, total manhours per
week, number of state certified or licensed personnel, staffing
deficiencies, staff vacancies, staffing needs not budgeted, training
needs, and annual O&M budgets. Also included will be an identifi-
cation and narrative of any facility problem traceable to personnel
or training deficiencies.
4. An identification and brief discussion of significant operational
problems or difficulties.
5. An evaluation and report on the facility including adequacy of
operation and plant performance with regard to state and federal
permit or other requirements, general housekeeping and maintenance
adequacy, testing and reporting adequacy, and recommendations for
corrective actions.
6. Appropriate additional operation and maintenance data and informa-
tion pertinent to the conditions found at the plant or elsewhere in
the sewage system at the time of inspection.
Every effort must be made to correct problems found during the evalua-
tion inspection. The wastewater facility operator and owner should be given
the necessary information, sources of technical help, and a reasonable time to
correct the problem.
If all else fails, the enforcement provisions of PL 92-500 Section
309(a)(3), 309(b), and 309(c) must be invoked. A failure to invoke this
enforcement provision has often existed in the past. Many wastewater treat-
ment facility owners do not believe that any type of legal action will be taken
against them. EPA must enforce all of its requirements if it expects proper
and effective plant operation and maintenance.
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The inspector conducting the O&M evaluation should become thoroughly
familiar with the contents of the Inspector's Guide for Evaluation of Municipal
Wastewater Treatment Plants, EPA 430/0-79-010.
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INSPECTION FEEDBACK
Introduction
A large amount of information on operation and
maintenance of a wastewater treatment plant can be
obtained during the inspection process. This infor-
mation can be a valuable aid in improving the design,
construction, operation, and maintenance of new and
existing treatment plants. State water pollution
control agencies and the EPA should develop a feedback system to get this
data back to the design engineers, contractors, grantee, operators, mainte-
nance personnel, inspector, etc. Participation in this feedback system should
be mandatory.
The use of a formal feedback system by all individuals involved in the
wastewater treatment industry yields many benefits and represents a tremen-
dous step toward the improvement of plant performance.
Importance
Incorporating feedback from the inspection experience of existing plants
into the design of new wastewater treatment plants can greatly improve a new
facility's ability to meet its effluent standards. The use of a feedback system
will aid the reviewer to enhance design features which improve plant perform-
ance and to eliminate the design deficiencies which detract from performance.
The inspector should make frequent visits to operating plants and plants
under construction. The undesirable features of past design concepts can be
brought to light in discussions with operators, construction field engineers,
and start-up personnel. Operator concerns and client dissatisfaction can be
detected, if they exist, by periodic visits and/or communications with the
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operator after plant start-up. These experiences can then be documented in
writing and used as a basis for required changes in design that will improve
facility O&M.
Purpose
The purpose of a feedback system should be to identify desirable design
features as well as to avoid undesirable features. Many desirable design
features can be incorporated into designs of new facilities based on plant
inspection feedback. Determination of strong and weak features of plant
designs can best be evaluated in light of direct plant inspection feedback.
Many advances in the state of the art of plant design and equipment features
have grown out of suggestions from operators, start-up personnel and resi-
dent representatives.
Sources of Feedback
Perhaps the most valuable single source of feedback is the information
gained from plant inspections and O&M evaluations reports. The information
obtained from these inspectors should be incorporated into the construction
grants process.
Incorporating Feedback into the Construction Grant Process
Access to a readily usable system of feedback data is essential to ensure
that the data will be used. There are a number of ways to accomplish this,
including various filing systems and computer oriented data handling systems.
In addition the agency could:
1. Develop in-house memorandum
2. Conduct group discussions among inspectors and plans and specifi-
cation reviews
3. Have inspectors present at preapplication, predesign, and/or pre-
construction conference
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6.
7.
INTERIM CONSTRUCTION INSPECTION
REVIEW OPERATION CHECKLIST
Preliminary plan of operation submitted and
approved with plans and specifications/Step 3
application.
Evidence of progress for completion of final plan
of operation for submittal and approval before
50 percent payment.
Draft O&M manual submitted and approved by
50 percent payment.
Evidence of progress for completion of final O&M
manual by 90 percent payment.
Start-up services subagreement/contract approved
with Step 3 grant award.
Provision for start-up underway.
O&M personnel (e.g., chief operator) hired,
trained, and certified.
a. Have influent characteristics, upon which
plans and specifications are based, been
confirmed?
b. Have errors in plans and specifications
(i.e., design) surfaced during inspections?
c. Have actions been taken to correct errors
in the plans and specifications?
Existing facility is in compliance with continuous
treatment requirements of its discharge permit
during construction.
CHECKLIST
YES NO NA
6-15
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YES NO NA
10. Equipment maintained and protected both in storage
and during construction.
11. Evidence of satisfactory completion of actions
specified in the approved preliminary and final
plan of operations.
12. Summary comment on grantee compliance with O&M requirements:
Signed:
Date:
6-16
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FINAL CONSTRUCTION INSPECTION
REVIEW OPERATION CHECKLIST
1. Final O&M manual approved and readily available
to O&M plant personnel
2. Final plan of operation approved
3. All elements of the plan of operation are completed
a. Adequate staff on board
b. Staff is trained adequately or is scheduled
for training
c. Records, reports, and laboratory control
d. Process control and start-up services
e. Safety
f. Emergency operating plan
g. Maintenance management
h. O&M manual
i. O&M budget
j. Other (e.g., sewer use ordinance, pretreat-
ment ordinance)
CHECKLIST
•
YES NO
NA
Evaluation of grantee's O&M program
Make entries: If further action or separate comment is required, circle
item number and reference the circled number in supplemental comments.
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PERSONNEL
a. Name, title, and telephone number of individual having primary responsi-
bility for overall O&M:
Minimum number of hours per day specifically assigned for this responsi-
bility:
Number of years of experience:
Certified? If No, what plans to remedy this?
Explain:
b. Total number of operating personnel:
c. Number certified:
d. Is staffing consistent with O&M manual recommendation?
START-UP TRAINING
a. Are personnel familiar with the O&M manual?
b. Who has provided them with related start-up instruction and supervision?
Name(s) and title(s):
c. Are shift operators, laboratory technicians, and supervisory personnel
familiar with effluent limitation and permit conditions?
d. Do they know what this means in terms of operating the facility under
all flow and load conditions?
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e. Is laboratory adequately equipped to perform necessary pretreatment,
influent, effluent, and process control testing?
f. Are daily logs maintained? Are laboratory results
recorded? Are monthly and other required reports
submitted to the state?
g. What arrangements have been made for updating the O&M manual?
h. What provisions have been made for annual O&M reports?_
OPERATING PROBLEMS
a. Are there operating problems affecting plant performance?
b. Can they be solved without major construction?
c. Does the staff have the necessary skills to solve these problems?
d. Were solutions suggested?
e. What followup actions(s) will be necessary?
f. Is operating budget adequate?_
g. Is maintenance program adequate?
OVERALL PLANT PERFORMANCE
a. Is plant operating at maximum design efficiency?
b. What are influent flow characteristics (flow and load) as confirmed by
sampling and analysis during construction?
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c. Comments on overall O&M program:
d. Is plant in compliance with NPDES permit (including reporting require-
ments)? If not, what plans have been made to comply?
By grantee:
By state:
By EPA:
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A P P E N DIX
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REGULATIONS
1. 40 CFR 30.615-3 Withholding of Funds
2. 40 CFR 30.915 Suspension of Grants--Stop-Work Orders
3. 40 CFR 30.915-1 Use of Stop-Work Orders
4. 40 CFR 30.920 Termination of Grants
5. 40 CFR 30.920-5 Annulment of Grant
6. 40 CFR 33.410-9 Award to the Low, Responsive, Responsible Bidder
7. 40 CFR 35.835-7 Operation and Maintenance
8. 40 CFR 35.835-9 Postconstruction Inspection
9. 40 CFR 35.917-1(a)(d)(h)
Contents of Facilities Plan
10. 40 CFR 35.917-4(b) Planning Scope and Detail
11. 40 CFR 35.917-5(a) Public Participation
12. 40 CFR 35.920-3(a) Contents of Application
13. 40 CFR 35.920-3(c)(3)
Contents of Application
14. 40 CFR 35.925-10 Operation and Maintenance Program
15. 40 CFR 35.927-4 Sewer Use Ordinance
16. 40 CFR 35.935-1 Grantee Responsibilities
17. 40 CFR 35.935-4 Step 2 and 3 Projects
18. 40 CFR 35.935-8 Supervision
19. 40 CFR 35.935-12 Operation and Maintenance
20. 40 CFR 35.935-14 Final Inspection
21. 40 CFR 35.965 Enforcement
A-2
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40 CFR 30.615-3
WITHHOLDING OF FUNDS
(a) It is EPA policy that full and prompt payment be made to the
gnantee for eligible project costs. Except as otherwise provided by this sub-
chapter, the EPA grant approving official may only authorize the withholding
of a grant payment where he determines in writing that a grantee has failed
to comply with project objectives, grant award conditions, or EPA reporting
requirements. Under such conditions, the EPA grant award official will
inform the grantee by written notice that payments will not be made for
obligations incurred after a specified date until the conditions are corrected.
Such withholding shall be limited to that amount necessary to assure compli-
ance.
(b) The grant approving official may authorize withholding of payment
to the extent of any indebtedness to the United States, unless he determines
that collection of the indebtedness will impair accomplishment of the project
objectives and that continuation of the project is in the best interest of the
United States.
40 CFR 30.915
SUSPENSION OF GRANTS--STOP-WORK ORDERS
Work on a project or on a portion or phase of a project for which a
grant has been awarded may be ordered stopped by the grant award official,
except for grants to educational institutions or nonprofit research organiza-
tions.
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40 CFR 30.915-1
USE OF STOP-WORK ORDERS
Work stoppage may be required for good cause such as default by the
grantee, failure to comply with the terms and conditions of the grant,
realignment of programs, lack of adequate funding, or advancements in the
state of the art. Inasmuch as stop-work orders may result in increased costs
to the Government by reason of standby costs, such orders will be issued
only after concurrence by the grant approving official and the Regional
Counsel or the Assistant General Counsel, Grants. Generally, use of a
stop-work order will be limited to those situations where it is advisable to
suspend work on the project or a portion or phase of the project for
important program or agency considerations and a supplemental agreement
providing for such suspension is not feasible. Although a stop-work order
may be used pending a decision to terminate by mutual agreement or for other
cause, it will not be used in lieu of the issuance of a termination notice after
a decision to terminate has been made.
40 CFR 30.920
TERMINATION OF GRANTS
A grant may be terminated in whole or in part by the grant award
official upon the recommendation of the ^roject Officer and after concurrence
of the grant approving official in the proposed action and consultation with
the Regional Counsel or the Assistant General Counsel, Grants.
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40 CFR 30.920-5
ANNULMENT OF GRANT
(a) The grant award official may unilaterally annul the grant if the
Project Officer determines, with the concurrence of the appropriate Assistant
Administrator or Regional Administrator and the Regional Counsel, Grants,
that:
(1) There has been no substantial performance of the project work
without good cause;
(2) There is convincing evidence the grant was obtained by fraud; or
(3) There is convincing evidence of gross abuse or corrupt practices in
the administration of the project.
(4) The grantee has inordinately delayed completion of the project
without good cause; or
(5) The grantee has failed to achieve the project purpose (e.g., prepa-
ration of a research report) or to utilize the project (e.g., construction)
to the extent that the fundamental purpose of the grant is frustrated.
40 CFR 33.410-9
AWARD TO THE LOW, RESPONSIVE, RESPONSIBLE BIDDER
(a) After bids are opened, they shall be evaluated by the grantee in
accordance with the methods and criteria set forth in the bidding documents.
(b) The grantee may reserve the right to reject all bids. The basis
for rejection must be stated by the grantee. Unless all bids are rejected for
good cause, award shall be made to the low, responsive, responsible bidder.
(c) If award is intended to be made to a firm which did not submit the
lowest bid, a written statement shall be prepared prior to any award and
A-5
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retained by the grantee explaining why each lower bidder was deemed not
responsive or not responsible.
(d) If EPA Project Officer approval is required by a special condition of
the grant agreement or by regulation, the subagreement shall not be executed
until approval has been obtained.
(e) Bidders shall be notified of the winner promptly after bid opening.
40 CFR 35.835-7
OPERATION AND MAINTENANCE
No grant may be awarded unless the applicant has made provisions
satisfactory to the Regional Administrator that the treatment works will be
maintained and operated in accordance with such requirements as the admin-
istrator may publish from time to time concerning methods, techniques and
practices for economics, and efficient, effective operation and maintenance of
treatment works. Such provision shall include, but not be limited to, (a) an
operation and maintenance manual, including emergency readiness plan, (b)
properly trained personnel and (c) operational reports.
40 CFR 35.835-9
POSTCONSTRUCTION INSPECTION
No grant may be awarded unless the State water pollution control agency
provides assurance satisfactory to the Regional Administrator that the State
will inspect the treatment works not less frequently than annually for the 3
years after such treatment works is constructed and periodically thereafter to
determine whether such treatment works is operated and maintained in an
efficient, economic, and effective manner.
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40 CFR 35.917-l(a)(d)(h)
CONTENTS OF FACILITIES PLAN
Facilities planning must address each of the following to the extent
considered appropriate by the Regional Administrator:
(a) A description of the treatment works for which construction draw-
ings and specifications are to be prepared. This description shall include
preliminary engineering data, cost estimates for design and construction of
the treatment works, and a schedule for completion of design and construc-
tion. The preliminary engineering data may include, to the extent appro-
priate, information such as a schematic flow diagram, unit processes, design
data regarding detention times, low rates, sizing of units, etc.
(d) A cost-effectiveness analysis of alternatives for the treatment works
and for the complete waste treatment system(s) of which the treatment works
is a part. The selection of the system(s) and the choice of the treatment
works for which construction drawings and specifications are to be prepared
shall be based on the results of the cost-effectiveness analysis.
3. An evalution of improved effluent quality attainable by upgrad-
ing the operation and maintenance and efficiency of existing
facilities as an alternative or supplement to construction of new
facilities.
(h) A brief statement demonstrating that the authorities who will be
implementing the plan have the necessary legal, financial, institutional, and
managerial resources available to insure the construction, operation, and
maintenance of the proposed treatment works.
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40 CFR 35.9l7-4(b)
PLANNING SCOPE AND DETAIL
(b) Facilities planning shall be conducted only to the extent that the
Regional Administrator finds necessary in order to insure that facilities for
which grants are awarded will be cost-effective and environmentally sound
and to permit reasonable evaluation of grant applications and subsequent
preparation of designs, construction drawings, and specifications.
40 CFR 35.917-5(a)
PUBLIC PARTICIPATION
(a) General. Consistent with section 101 (e) of the Clean Water Act and
40 CFR Part 25, EPA, the States, and grantees shall provide for, encourage,
and assist public participation in the facilities planning process and shall
provide citizens with information about and opportunities to become involved
in the following:
1. The assessment of local water quality problems and needs;
2. The identification and evaluation of locations for wastewater treat-
ment facilities and of alternative treatment facilities and alternative
treatment technologies and systems including those which recycle
and reuse wastewater (including sludge), use land treatment,
reduce wastewater volume, and encourage multiple use of facilities;
3. The evaluation of social, economic, fiscal, and environmental im-
pacts; and
4. The resolution of other significant facilities planning issues and
decisions.
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40 CFR 35.920-3(a)
CONTENTS OF APPLICATION
(a) Step 1: Facilities plan and related Step 1 elements. An application
for a grant for Step 1 shall include:
1. A plan of study presenting:
(i) The proposed planning area;
(ii) An identification of the entity or entities that will be conduct-
ing the planning;
(iii) The nature and scope of the proposed Step 1 project and
public participation program including a schedule for the
completion of specific tasks;
(iv) An itemized description of the estimated costs for the project;
and
(v) Any significant public comments received.
40 CFR 35.920-3(c)(3)
CONTENTS OF APPLICATION
(c) Step 3. Building and erection of a treatment works. Prior to the
award of a grant or grant amendment 1or a Step 3 project, the applicant must
furnish the following:
(3) A schedule for or evidence of compliance with 35.925-10 and
35.935-12 concerning operation and maintenance program, including
a preliminary plan of operation.
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40 CFR 35.925-10
OPERATION AND MAINTENANCE PROGRAM
If the award of a grant assistance is for a Step 3 project, that the
applicant has made satisfactory provision to assure proper and efficient opera-
tion and maintenance of the treatment works (including sewer system) in
accordance with 35.935-12 and that the State will have an effective operation
and maintenance monitoring program to assure that treatment works assisted
under this subpart comply with applicable permit and grant conditions.
40 CFR 35.927-4
SEWER USE ORDINANCE
Each applicant for grant assistance for a Step 2 or Step 3 project shall
demonstrate to the satisfaction of the Regional Administrator that a sewer use
ordinance or other legally binding requirement will be enacted and enforced in
each jurisdiction served by the treatment works project before the completion
of construction. The ordinance shall prohibit any new connections from
inflow sources into the sanitary sewer portions of the sewer system and shall
insure that new sewers and connections to the sewer system are properly
designed and constructed.
40 CFR 35.935-1
GRANTEE RESPONSIBILITIES
(a) Review or approval of project plans and specifications by or for
EPA is for administrative purposes only and does not relieve the grantee of
its responsibility to design, construct, operate, and maintain the treatment
works described in the grant application and agreement.
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(b) By its acceptance of the grant, the grantee agrees to complete the
treatment works in accordance with the facilities plan, plans and specifica-
tions, and related grant documents approved by the Regional Administrator,
and to maintain and operate the treatment works to meet the enforceable
requirements of the Act for the design life of the treatment works. The
Regional Administrator is authorized to seek specific enforcement or recovery
of funds from the grantee, or to take other appropriate action (see 40 CFR
35.965), if he determines that the grantee has failed to make good faith
efforts to meet its obligations under the grant.
(c) The grantee agrees to pay, pursuant to section 204(a)(4) of the
Act, the non-Federal costs of treatment works construction associated with
the project and commits itself to complete the construction of the operable
treatment works and complete waste treatment system (see definitions in 40
CFR 35.905) of which the project is a part.
(d) The Regional Administrator may include special conditions in the
grant or administer this subpart in the manner which he determines most
appropriate to coordinate with, restate, to enforce NPDES permit terms and
schedules.
40 CFR 35.935-4
STEP 2 AND 3 PROJECTS
A grantee which has received Step 2 and 3 grant assistance must make
submittals required by 40 CFR 35.920-3(c), together with approvable user
charge and industrial cost recovery systems and a preliminary plan of opera-
tion. The Regional Administrator shall give written approval of these sub-
mittals before advertising for bids on the Step 3 construction portion of the
Step 2 and 3 project. The cost of Step 3 work initiated before such approval
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is not allowable. Failure to make the above submittals as required is cause
for involving sanctions under 40 CFR 35.965.
40 CFR 35.935-8
SUPERVISION
In the case of any project involving Step 3, the grantee will provide and
maintain competent and adequate engineering supervision and inspection of the
project to ensure that the construction conforms with the approved plans and
specifications.
40 CFR 35.935-12
OPERATION AND MAINTENANCE
(a) The grantee must make provision satisfactory to the Regional Admin-
istrator for assuring economic and effective operation and maintenance of the
treatment works in accordance with a plan of operation approved by the state
water pollution control agency or, as appropriate, the interstate agency.
(b) As a minimum, the plan shall include provisions for:
1. An operation and maintenance manual for each facility;
2. An emergency operating and response program;
3. Properly trained management, operation, and maintenance
personnel;
4. Adequate budget for operation and maintenance;
5. Operational reports;
6. Provisions for laboratory testing and monitoring adequate to
determine influent and effluent characteristics and removal
efficiencies as specified in the terms and conditions of the
NPDES permit.
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7. An operation and maintenance program for the sewer system.
(c) Except as provided in paragraphs (d) and (e) of this section, the
Regional Administrator shall not pay:
1. More than 50 percent of the Federal share on any Step 3
project unless the grantee has furnished a draft of the opera-
tion and maintenance manual for review, or adequate evidence
of timely development of such a draft; or
2. More than 90 percent of the Federal share unless the grantee
has furnished a satisfactory final operation and maintenance
manual.
(d) In projects where segmenting of an operable treatment works has
occurred, the Regional Administrator shall not pay:
1. More than 50 percent of the Federal share of the total of all
interdependent Step 3 segments unless the grantee has fur-
nished a draft of the operation and maintenance manual for
review, or adequate evidence of timely development of such a
draft, or
2. More than 90 percent of the Federal share of the total of all
interdependent Step 3 segments unless the grantee has fur-
nished a satisfactory final operation and maintenance manual.
(e) In multiple facility projects where an element or elements of the
treatment works are operable components and have been completely construc-
ted and placed in operation by the grantee, the Regional Administrator shall
not make any additional Step 3 payment unless the operation and maintenance
manual (or those portions associated with the operating elements of the treat-
ment works) submitted by the grantee has been approved by the Regional
Administrator.
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40 CFR 35.935-14
FINAL INSPECTION
The grantee shall notify the Regional Administrator through the State
agency of the completion of Step 3 project construction. The Regional
Administrator shall cause final inspection to be made within 60 days of the
receipt of the notice. When final inspection is completed and the Regional
Administrator determines that the treatment works have been satisfactorily
constructed in accordance with the grant agreement, the grantee may make a
request for final payment under 35.945(e).
40 CFR 35.965
ENFORCEMENT
If the Regional Administrator determines that the grantee has failed to
comply with any provision of this subpart, he may impose any of the following
sanctions:
(a) The grant may be terminated or annulled under 30.920 of this
subchapter;
(b) Project costs directly related to the noncompliance may be disal-
lowed;
(c) Payment otherwise due to the grantee of up to 10 percent may be
withheld (see 30.615-3 of this chapter);
(d) Project work may be suspended under 30.915 of this subchapter;
(e) A noncomplying grantee may be found nonresponsible or ineligible
for future Federal assistance or a noncomplying contractor may be found
nonresponsible or ineligible for approval for future contract award under EPA
grants;
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(f) An injunction may be entered or other equitable relief afforded by
a court of appropriate jurisdiction;
(g) Such other administrative or judicial action may be instituted if it is
legally available and appropriate.
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REFERENCES
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REFERENCES
The following references used are available from:
General Services Administration (8FSS)
Centralized Mailing Lists Services
Bldg 41, Denver Federal Center
Denver, Colorado 80225
1. How To Obtain Federal Grants to Build Municipal Wastewater Treatment
Works MCD-04 USEPA
2. Construction Grants Program for Municipal Wastewater Treatment Works:
Handbook of Procedures MCD-03 USEPA
3. Guidance for Preparing a Facility Plan MCD-05 USEPA
4. Model Plan of Study MCD-24 USEPA
5. Design Criteria for Mechanical, Electrical, and Fluid System and
Component Reliability MCD-50 USEPA
The following references used are available from:
Superintendent of Documents
U.S. Government Printing Office
Washington, D.C. 20402
6. Consideration for Preparation of Operation and Maintenance Manuals,
USEPA 430/9-74-001 price $3.10 Stock # 055-001-00644-6
7. Start-up Services of Municipal Wastewater Treatment Facilities, USEPA
430/9-74-008 price $1.40 Stock # 055-001-0763-9
8. Estimating Staffing for Municipal Wastewater Treatment Facilities, USEPA
price $3.00 Stock ft 055-001-00569-5
9. Emergency Planning for Municipal Wastewater Treatment Facilities, USEPA
430/9-74-002 price $1.25 Stock # 055-001-00778-7
10. Estimating Laboratory Needs for Municipal Wastewater Treatment Facilities
price $1.45 Stock # 055-001-0651-9
11. Federal Guidelines:
Design of Wastewater Treatment Facilities, February 1976
Inquiries pertaining to this document should be directed to:
U.S. Environmental Protection Agency
Office of Water Program Operations
Washington, D.C. 20460
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12. Federal Guidelines:
Operation and Maintenance of Wastewater Treatment Facilities
Inquiries pertaining to this document should be directed to:
U.S. Environmental Protection Agency
Office of Water and Hazardous Materials
Washington, D.C. 20460
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