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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