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
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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-
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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
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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
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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
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