United States Environmental Protection Agency Water Engineering Research Laboratory Cincinnati, OH 45268 Research and Development EPA/600/S2-87/030 June 1987 &EPA Project Summary Model Statewide Compliance Strategy Incorporating the Composite Correction Program (CCP) Concept James R. Schultz, Bob A. Hegg, Charles S. Zickefoose, Fred Matter, and Francis L Evans III A Composite Correction Program (CCP) identifies causes of performance problems at publicly owned treatment works (POTW's), addresses them sys- tematically and in order of priority of impact on plant capability, and de- scribes solutions to problems. CCP ob- jectives are to improve performance and to bring noncomplying POTW's into compliance. The purposes of this study were to demonstrate the use of the CCP concept on a statewide basis to improve compliance and to develop criteria to incorporate the CCP concept into the State of Colorado's municipal compliance enforcement strategy. The study selected 16 plants for on- site plant evaluations, typically lasting 3 to 5 days. The major objectives of these comprehensive evaluations were to determine actual compliance status, identify specific factors limiting per- formance, and assess the potential im- provement in performance which could be achieved with a CCP. "Limited" COP'S were initiated at five of the plants which were most suitable for demon- strating the objectives of this project. Limited refers to making minor modifi- cations not involving major construc- tion. Performance was improved during 4 of the 5 CCP's and during 3 of the other 11 comprehensive evaluations. Through interviews conducted with plant owners, managers, and state pol- lution control authorities, conclusions were developed regarding the ele- ments that should be considered in the development of an enforcement strat- egy. These elements then serve as the framework for developing a municipal compliance and enforcement policy and implementation program compat- ible with most state environmental agencies. The conclusions were: • Whether a state adopts an official compliance strategy or not, im- proved performance and increased compliance by municipal plants is unlikely without consistent en- forcement efforts by the regulatory agencies. • Owners of wastewater facilities must be clearly established as the party primarily responsible for methods and funding to achieve re- quired POTW performance and compliance. • Grant or loan funding programs, in- cluding their implementation and administration, should be struc- tured to encourage increased local fiscal responsibility. • Local administrators should be made aware of the CCP option to improve POTW performance. • Regulatory agencies must focus on establishing necessary water qual- ity standards and associated indi- vidual facility effluent limits, and enforcing these limits. This Project Summary was devel- oped by EPA's Water Engineering Re- search Laboratory, Cincinnati, OH, to announce key findings of the research project that is fully documented in a ------- separate report of the same title (see Project Report ordering information in back). Introduction In the late 1970's, the U.S. Environ- mental Protection Agency funded sev- eral research projects to identify the problems preventing a large number of publicly owned treatment works (POTW's) from meeting required efflu- ent limits. These studies documented that each facility has a unique combina- tion of limiting factors. Analysis of the complex interrelation- ship of varied performance limiting fac- tors together with the ineffectiveness of state and federal programs designed to eliminate these factors led to the devel- opment of a unified concept for achiev- ing optimum plant performance. The concept included the identification of performance limiting factors in admin- istration, maintenance, operation, and design; and described how each factor could be individually eliminated, par- tially eliminated, or left unaddressed by existing programs associated with pub- lic wastewater treatment. The concept also related optimum performance to the many performance limiting factors associated with each plant. The correc- tion of only some of the factors limiting performance will not result in the de- sired improved effluent quality at a par- ticular plant. The approach for improving plant performance was called a Composite Correction Program (CCP). A CCP is based on optimizing the performance of an existing facility by eliminating prob- lems in administration, design, opera- tion, and maintenance. A major differ- ence between the CCP and many existing programs is that a CCP concen- trates on eliminating all factors con- tributing to poor plant performance at an individual plant, whereas existing programs typically concentrate on specific areas of need representing problems common to a large number of treatment facilities. Through an EPA cooperative agree- ment, the Colorado Department of Health (CDH) has demonstrated that the CCP concept can be incorporated into the state's compliance enforcement program and that compliance levels at noncomplying POTW's can be in- creased. In addition, critical elements of a compliance strategy that incorporates the CCP have been identified and the framework of a model enforcement pro- gram has been developed. Procedure A selection procedure was used to de- termine the Colorado POTW's used as demonstration facilities for CCP's. The selection process involved two major steps of screening: in-office screening using previously developed data and in- plant evaluations of selected facilities by the contractor. In-office screening was accomplished as a joint effort between the contractor, CDH personnel, and EPA Region VIII personnel. Compliance and inspeciton report information was supplemented with personal knowledge of facilities to identify those POTW's most suitable for implementing CCP's. State district engi- neers were consulted regarding some facilities and were asked to suggest additional possible facilities. Key con- siderations in selecting POTW's for the in-plant evaluations were mechanical/ biological plant; noncompliance with respect to BOD5, TSS, and fecal coliform parameter regulations; and absence of construction activity. Upon evaluation, the plants were given a classification of Type I through Type IV: Type I—Complying with effluent re- quirements. Type II—Non-compliance (enforce- able documentation). Type III—Marginally out of compli- ance. Type IV—Performance suspect. The 16 treatment facilities in the Type II through Type IV categories were se- lected for the in-plant performance eval- uation, termed "Comprehensive Evalu- ation" (CE). A formal request for each facility's involvement in the CCP project was accomplished through a letter sent by CDH to each facility administrator. The letters explained the scope of the project; however, the wording of each letter varied depending on the plant type (i.e., II, III, IV). After the letters were sent, each owner was contacted by the contractor to establish a time to conduct a compre- hensive evaluation. Comprehensive evaluations were typically conducted by two operations engineers over a 3- to 5-day period. The initial step of each evaluation was a meeting between the evaluation team and the facility admin- istrators. The purpose of the interviews was to improve local understanding of the project and its consequences, evalu- ate administrators' knowledge of the treatment plant and its status, and as- sess the owners' attitudes on plant com pliance and regulatory agency roles. The in-plant work at each facility iden tified factors limiting performance anc evaluated the performance potential o those facilities. Discussions with the staff were used to document existinc operation and maintenance procedures The existing loadings on treatmem processes were obtained through fielc measurements and a review of plant records and drawings. Based on this in- formation, a performance potential table was developed that provided an estimated capacity for each treatment process. Each report classified the sub- ject facility according to the potential for improving performance using a CCP limited to the scope available within the project. Each facility evaluated was clas- sified according to the following: Type A - Permit compliance with final limits can be achieved by conducting a CCP without major capital improve- ments. Type B - Significantly improved per- formance can be achieved with a CCP, but consistent compliance with final limits is not likely without a major upgrade. Type C- Significantly improved per- formance would not result from a CCP. Composite Correction Programs were conducted at five treatment facilities. The length of the CCP's ranged from 4 months to 12 months. Each CCP was carried out by the project personnel who had conducted the respective com- prehensive evaluation. The CCP's were implemented using periodic onsite and telephone consulta- tions between the contractor and the fa- cility staff. The major factors limiting performance, which had been identified in the comprehensive evaluation, were initially addressed in the CCP. The CCP emphasis was to eliminate factors limit- ing performance until desired effluent quality was achieved. Necessary modi- fications to plant operation and design required a coordinated effort among the contractor, the owner, and, in some cases, the owner's engineer. At some plants, recommended operational mod- ifications (e.g., sludge hauling) would have been financially restrictive for the owner and impossible to fund within the time frame of the research study. In these cases, less costly methods of ac- complishing the same result were in- ------- vestigated and implemented if feasible. :or this demonstration project, the CCP was considered successful and com- plete when the desired effluent quality was maintained for 4 consecutive months. Based on a point scoring system that assigns values related to the extent of adverse impact, the highest ranking fac- tors collectively identified at plants in this study are listed in Table 1. Of the 16 facilities evaluated, 10 were activated sludge facilities, 5 used trickling filters, and 1 was an aerated lagoon. Highest ranking factors for the activated sludge and the trickling filter facilities were cal- culated individually. The top ranking factors limiting performance were very similar for these two categories of facil- ities. The top ranking factors limiting per- formance illustrate the complexity of most problems limiting wastewater plant performance. Inadequacies in the areas of sludge treatment and disposal, aerators, clarifiers, disinfection, process flexibility, and process return streams all indicate that design limitations exist in the plants studied. Poor operator ap- plication of concepts and testing indi- cates that many plants could improve operation by application of process con- troVprinciples. In addition, plant admin- istrators' unfamiliarity with plant needs and the dissemination of improper tech- nical guidance by "authoritative sources" also limit the potential of exist- ing facilities. The most obvious conclu- sion drawn from analyzing the top fac- tors limiting performance is that no single group—operators, engineers or administrators—is responsible for the problems. Improved performance at any one facility requires that all individ- uals focus on that common goal. Performance associated with the CCP's in the Colorado project is summa- rized in Table 2. In the comprehensive evaluations preceding each CCP, the performance level expected from a lim- ited CCP was predicted. In this study, a limited CCP was initiated at selected plants to demonstrate improved per- formance with existing facilities. This contrasts with the originally developed total CCP concept, which includes all plant modifications or additions, onsite training to improve operator cap- abilities, and extended onsite- and telephone-consultation to monitor and fine-tune process performance. All five facilities were routinely out of compliance at the time of the compre- Table 1. Combined Ranking of Factors Limiting Performance Rank Factor Total Points 1 1 3 4 5 6 7 8 8 10 10 Ultimate Sludge Disposal Operator Application of Concepts and Test- ing to Process Control Aerator Infiltration/Inflow Clarifier Improper Technical Guidance Disinfection Administration Familiarity with Plant Needs Sludge Treatment Return Process Streams Process Flexibility 24 24 16 14 13 11 9 8 8 7 7 Table 2. Performance Predicted and Achieved Facility Long Term Performance Predicted from CE Actual Improvement Achieved within 4 months Brighton Morrison Littleton/Englewood Montrose Idaho Springs Improved but not to secondary Improved Performance Final limits, 30/30 Improved Performance Final limits, 20/20 Improved but not to secondary Meet interim, 50/50 Meet final, 30/30 half time Improved but not to sec- ondary Improved Performance Final Limits Improved Performance Not Final limits No improvement Improved Performance Meet Interim Not 30/30 half time hensive evaluations. It was predicted that two of the facilities could be brought into compliance with final limits by using the proposed CCP. At the other three plants, improvements in performance but not compliance with final limits could be expected. At three additional plants where limited CCP's were started, the additional work re- vealed previously undetectable prob- lems requiring modifications more ex- tensive than originally estimated for the plants to meet final limits. Therefore, these CCP's were terminated. These re- sults illustrate the findings of the origi- nal research that led to the development of the CCP concept: to cost-effectively improve performance in a wastewater facility, any and all factors that limit per- formance must be systematically ad- dressed and eliminated until the desired performance level is achieved. Based on the Colorado demonstration project results, it appears that the level of effort predetermined by the comprehensive plant evaluation will be successful in improving performance at some plants but will be inadequate in other plants. As shown in Table 2, performance was improved in four of the facilities, but not always to the levels predicted in the comprehensive plant evaluations. Specific circumstances were discussed in the individual CCP reports. In general, the factors limiting plant performance were correctly identified in the compre- hensive evaluations, but project time and budget constraints limited the fac- tors that could be adequately addressed by the limited CCP's in this project. The results further point out that, al- though the plant performance evalua- tions are comprehensive, a CE alone will not always accurately predict the extent of corrections required. From previous applications of the CE/CCP process, additional problems and new priorities are generally found during the CCP activities. These are found only after corrections are made and would ------- not have come to light without correct- ing and eliminating the original or more obvious problems. Because the CE/CCP is a continuing effort of discovery, it is clear that commitment by plant admin- istration to only a predetermined list of plant improvements (i.e., a limited CCP) will likely produce only limited improve- ments in performance and possible fail- ure to achieve the goal of compliance. The costs associated with plant evalu- ations and the implementation of a CCP would generally be incurred by individ- ual communities. It is not intended that the state assume the responsibility for meeting the long-term wastewater treatment needs of selected communi- ties. The CCP costs that would ordinarily have been incurred by the respective communities in this study are shown in Table 3. The expenses were limited to those necessary to demonstrate im- proved performance by maximizing ef- fectiveness of the existing facilities. The costs did not include those that would be incurred when plant modifications or additions, long-term operator training, and all improvements required to achieve the performance and compli- ance goals are made. Municipalities' Views on Compliance Interviews were held with cognizant city and treatment plant personnel at the 16 facilities where CE's were com- pleted regarding the conduct of com- prehensive plant evaluations and the implementation of CCP's. It was con- cluded that there is little incentive to im- prove the performance of existing plants because of the possibility of re- ceiving Federal grant funding. Administrators who represented the facility owners were interviewed twice during each comprehensive evaluation: once prior to the evaluation, and once at the end. These interviews were used to Table 3. CCP Costs Estimated Cost of CCP Actual Cost of "Limited" CCP Morrison CCP Consultant Other Costs TOTAL Idaho Springs CCP Consultant Other Costs TOTAL Littleton/Englewood CCP Consultant Other Costs TOTAL Montrose CCP Consultant Other Costs TOTAL Brighton CCP Consultant Other Costs TOTAL $ 8,900 12,420 $ 21,320* $ 8,000 11,900 175,000* $194,900* $ 84,000 78,000 $162,000* $ 9,000 12,000 $ 21,000* $ 9,800 23,300 $ 33,100* $ 5,200 8,325 $13,525 $ 4,400 15,600 $20,000 $9,180 expended prior to termination of this CCP $ 3,700 20,700 $24,400 $ 5,000 4,525 $ 9,525 * "Limited" CCP fCost of modifications completed by the City prior to and during the CCP. #Full CCP discuss such things as responsibilities priorities, regulatory agencies, and thi current plant status, as well as the inten tions and results of the facility eval uations. Administrative response: obtained during the interviews are sum marized as follows: • All administrators felt some re- sponsibility for their plant. Their as- sessment of whether or not they met that responsibility usually was not directly related to plant per- formance. • Minimizing local costs and obtain- ing Federal grants were generally viewed as the best ways adminis- trators could meet their overall re- sponsibility. • Most administrators of plants not in compliance believed they could not comply without a grant. • Sampling and reporting in at least two cities was according to permit, but not representative of true per- formance. • Enforcement activities dramatically increased administrators' aware- ness of plant performance. • Local administrators believe CDH's primary role is to provide assis- tance to the local community. Local administrators do not recognize that the Department's ultimate re- sponsibility is for overall protection of Colorado waters. • Strong continued enforcement action by the State of Colorado pro- vided the incentive for one commu- nity to replace personnel in posi- tions as high as the Director of Public Works. Continuous compli- ance resulted and wastewater treat- ment is now operated as a self- supporting utility. Enforcement Strategy: Key Elements Encouraged by the demonstrated im- proved performance possibilities and the potential cost savings when a clear focus on achieving required effluent quality is pursued, a compliance strat- egy framework was developed. The strategy conceptually outlines activities required to overcome the observed roadblocks for owners/administrators and regulatory agency personnel. Key elements which define specific points of view for consideration and adoption by a federal, state or other areawide governing body (i.e., county or regional council of governments) are presented. Procedural requirements ------- and party responsibility for action are identified for development of a compli- ance strategy which accommodates the research conclusions. The recommen- dations are not all-inclusive but instead demonstrate the method of factoring the research conclusions into specific day-to-day activities. It is believed that compilation of these specific actions will lead to improved local and area- wide compliance at municipal waste- water treatment plants. Although the key elements developed represent activities for a regulatory agency, factoring the specific activities of facility owners, consultants, opera- tors, and others into the strategy frame- work could also be considered. Regulatory agencies must clearly demonstrate a willingness to pursue ag- gressive enforcement of effluent com- pliance. In doing so, regulatory agen- cies best direct owners/administrators by clearly focusing the attention of local officials on their responsibility for achieving required effluent quality. However, effective enforcement re- quires establishment of reasonable water quality standards upon which ef- fluent standards can be based; stand- ards that result in a clear target for local officials. Enforcement or the threat of enforcement by a state agency for a local facility to achieve effluent compli- ance provides the "outside authority" that acts on behalf of the general pub- lic's interest to protect overall water quality. The outside incentive is neces- sary so that local officials may achieve required performance by increasing pri- ority and funding commitment on a local basis. Regulatory agencies have difficulty offering technical and operational assis- tance to individual communities while providing effective motivational en- forcement. Providing assistance inter- feres with establishing owners and ad- ministrators as the party responsible for plant performance. If a state chooses to provide assistance to individual com- munities, the efforts must be clearly separated from the regulatory function. An understanding between the local community and the state assistance personnel must be reached concerning responsibility for the plant's effluent quality. Focusing local priorities on achieving adequate treatment must be supple- mented by awareness of a need for in- creased local financial responsibility. Consistent enforcement pressure plus increased local responsibility would en- courage local officials to develop a self- sustaining utility approach toward meeting their wastewater treatment re- sponsibilities. Desired plant perform- ance can be achieved despite reduced grant support. Technical personnel can become adept at achieving compliance with existing facilities so that large cap- ital improvement projects would only be implemented when truly necessary. Key elements necessary to encourage this outcome are aggressive enforce- ment focused on effluent compliance coupled with an emphasis on local re- sponsibility for plant performance and compliance. The full report was submitted in fulfill- ment of Cooperative Agreement No. CR 807191 by Colorado Department of Health under the sponsorship of the U.S. Environmental Protection Agency. When the work was being performed, James R. Schultz and Bob A. Hegg were with M & I Consulting Engineers, Fort Collins, CO 80521; Charles S. Zickefoose was with Brown & Caldwell, Inc., Portland, OR 97232; Fred Matter was with the Colorado Department of Health, Denver, CO 80220; the EPA author Francis L. Evans III (also the EPA Project Officer, see below) is with the Water Engineering Research Laboratory, Cincinnati, OH 45268. James R. Schultz is currently with Donohue & Associates, Inc., Fort Collins, CO 80525 and Bob A. Hegg is with Process Applications, Inc., Fort Collins, CO 80525. The complete report entitled "Model Statewide Compliance Strategy Incorporating the Composite Correction Program fCCP) Concept," (Order No. PB 87-181 418/AS; Cost: $18.95, subject to change) will be available only from: National Technical Information Service 5285 Port Royal Road Springfield, v'A 22161 Telephone: 703-487-4650 The EPA Project Officer can be contacted at: Water Engineering Research Laboratory U.S. Environmental Protection Agency Cincinnati, OH 45268 ------- United States Center for Environmental Research BULK RATE Environmental Protection Information POSTAGE & FEES PA Agency Cincinnati OH 45268 EPA PERMIT No G-35 Official Business Penalty for Private Use $300 EPA/600/S2-87/030 II ••Mia ST IL 60404 ------- |