600J87998
ASSESSMENT OF I/A FACILITIES SEEKING
100 PERCENT MODIFICATION/REPLACEMENT
FUNDING - CASE HISTORIES
by
Arthur J. Condren
James M. Montgomery Consulting Engineers, Inc.
Pasadena, California
Bob A. Hegg
1 Process Applications, Inc.
Fort Collins, Colorado
X>
^v Jon H. Bender
•• U.S. Environmental Protection Agency
i. Cincinnati, Ohio
Madan L. Arora
James M. Montgomery Consulting Engineers, Inc.
Pasadena, California
for
59th Annual Conference
of the
Water Pollution Control Federation
Los Angeles, California
October 1986
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INTRODUCTION
The 1977 Amendments to the Clean Water Act (P.L. 95-217) provide incen-
tives to municipalities for selecting innovative and/or alternative
(I/A) technologies for treating their wastewaters. I/A technologies, by
definition, are less expensive to construct or operate than conventional
systems, but have a risk associated with their capability to provide the
required performance. To offset this risk, Section 202(a)(3) of P.L.
95-217 provides for the U.S. EPA to pay for 100 percent of the cost of
modification or replacement of an I/A system which fails to achieve its
anticipated performance. Modification or replacement of the I/A system
is undertaken to ensure treatment system performance goals will be
realized.
The request for a 100 percent modification/replacement (100% M/R) grant
must be initiated by the municipality. The guidelines that the munici-
pality must pursue to obtain such a grant are presented in Section 15.2
of the U.S. EPA's Construction Grants guidance document (CG-85). '
Part of these guidelines requires the U.S. EPA to confirm that the I/A
technology has been in operation for at least two years, has not been
hydraulically or organically overloaded, and has been adequately oper-
ated and maintained. At some point, the agency must also establish
that: the I/A portion of the wastewater treatment system has caused
the claimed failure or has significantly increased the capital and/or
0 & M costs of the facility, and the claimed I/A technology failure is
not attributable to negligence on the part of any individual.
Once an initial screening of available information has indicated the
claimed failure of the I/A technology is probable, CG-85 recommends the
preparation of a performance evaluation report which includes:
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A description of the claimed failure.
A quality assurance review of environmental data utilized to
document the claimed failure.
- An assessment of the facility's 0 & M program.
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- An evaluation of the entire wastewater facility design.
The identification and evaluation of any construction defi-
ciencies contributing to the claimed failure.
- An evaluation of equipment performance and warranties.
- An evaluation of process warranties and performance guaran-
tees.
- A description of any outstanding claims and issues of negli-
gence.
Because the Comprehensive Performance Evaluation (CPE) analyzes all fac-
tors contributing to facility non-compliance, the technique was evalu-
ated to determine if it was suitable for meeting some of the CG-85
requirements. The CPE technique is part of the Composite Correction
Program (CCP) procedure^ ' which was developed by the U.S. EPA to
address discharge permit non-compliance at publically owned treatment
works (POTWs). A CPE identifies the unique combination of design, oper-
ational, maintenance and administrative factors responsible for facility
non-compliance, and interprets whether a follow-up CCP could be used as
the most expedient and cost-effective alternative for achieving compli-
ance. A CCP is a site specific program which, when implemented, system-
atically addresses the factors identified in a CPE. Typically CCP
activities would not include major modifications or construction.
The CPE portion of the CCP approach (CPE) addresses many of the CG-85
requirements for assessing 100% M/R requests. To formally assess the
applicability of the approach, a project was initiated whereby a limited
number of facilities that had requested 100% M/R funding would be evalu-
ated using CPE procedures. This paper presents the results of this
effort.
APPROACH
Five facilities that had claimed failures of installed I/A systems were
evaluated. The evaluations at each facility were typically conducted
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during a one week period by a two-person CPE team. Activities during
the CPE included:
- A kick-off meeting to inform the City administration and plant
staff of the CPE activities and goals as well as what would be
required of them during the site visit.
- A detailed tour of the entire wastewater treatment plant conducted
by the facility's process control decision-maker(s).
A review of the 0 & M Manual, specifications, equipment literature
and record drawings to obtain design information on all installed
unit processes.
- A review of operational records to allow for development of flow
and mass balances associated with each major unit process at the
wastewater treatment plant. This step also allowed some veri-
fication of laboratory results.
The development of a unit process potential capacity graph to allow
for a comparison of unit process estimated capacity with both cur-
rent and design loadings.
The conduct of individual interviews with the treatment plant oper-
ations, maintenance and laboratory staff members, City adminis-
trators, the facility design engineer, and in certain cases, the
manufacturer of the I/A system equipment. Interview questions cen-
ter on each individual's general role in and understanding of the
overall facility design, operation, maintenance and administra-
tion. In addition, specific questioning was oriented toward the
claimed I/A technology failure.
The identification and ranking in order of priority by the CPE team
members of design, operational, maintenance and administrative
factors currently limiting, or potentially limiting in the future,
the overall performance of the POTW. This comprehensive identifi-
cation/ranking was undertaken without regard to interaction with
conventional or I/A treatment system components.
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An exit meeting attended by the CPE team members as well as the
individuals interviewed by the CPE team. Staff members from the
State regulatory, .agency. ,aad from the U.S. EPA regional office were
also invited to this meeting. The purpose of the meeting was to
verbally present the preliminary findings of the week-long CPE.
- A written report which was subsequently distributed to the munici-
pality and involved regulatory agencies for their use in addressing
the claimed failure and the request for a 100% M/R grant.
Limited changes were made in the CPE approach for the evaluation of the
facilities requesting 100% M/R funding. Additional effort was made to
determine which portion of the facility had been constructed with an I/A
grant and additional investigation of the I/A facilities occurred during
the personnel interviews.
FIELD ACTIVITIES
The results of the CPEs undertaken at five POTWs that had claimed fail-
ures of installed I/A systems are discussed in this section. It is
noted that this paper avoids the discussion of specific I/A technologies
since the purpose of the evaluations was to assess the use of the CPE
procedures. Substantial information is presented on the first case
study. This has been done to provide the reader with a better under-
standing of the methodologies involved in the CPE procedure. Case stud-
ies two through five are much more succinct in presentation, highlight-
ing just the findings of the investigative efforts.
Site Visit 1
o
Facility 1 was a 3,785 mj/day (1.0 mgd) secondary treatment plant
i
designed for nitrification as well as removal of the more conventional
parameters, BOD and TSS. The municipality received I/A funding for a
high efficiency aeration system, and for the aeration basin, secondary
clarifier and waste secondary sludge holding tank based primarily on
their common-wall construction. A schematic of the facility is shown in
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Figure 1. Two claims of I/A technology failures were declared by the
municipality: 1) the aeration system was inadequate to provide for
proper wastewater treatment at greater than the current— f-l«w--r-ate of
o
1,514 m /day (0.4 mgd), and 2) the secondary clarifier was subject to
freeze-up during periods of cold weather. A 100% M/R request for sup-
plemental aeration equipment and a secondary clarifier cover were being
pursued.
In an attempt to provide better definition to the first claimed failure,
facility performance data over the past year were reviewed and compared
to the limitations stipulated in the facility's NPDES permit. The out-
come of this effort is summarized in Table 1.
TABLE 1. Evaluation of Data for Plant 1
CONDITION
PARAMETER
Flow
m-Vday
mgd
Influent
BOD mg/L
TSS, mg/L
NH.-N, mg/L
TO, mg/L
Effluent**
BOD mg/L
TSS, mg/L
NH -N, mg/L
TKN, mg/L
CURRENT
1,514
0.4
250
210
26
43
18/17
30/24
8.0/-
-/20.6
PERMIT
3,785
1.0
200*
200*
20*
30*
20/30
30/30
2.37-
-/8.0
* - Design values
** - Summer/winter values
It appeared that the claimed failure was probable since the I/A facili-
ties had been operating at loadings significantly less than design
capacity and had still failed to consistently meet desired effluent
standards. However, further data and information analysis 'during the
CPE field activities indicated a projected loss of about 58,050 kg
(128,000 Ib) of TSS from the treatment system during the previous one-
year period. Probable cause of this TSS loss was inadequate sludge mass
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control in the system coupled with solids washout due to a collection
system inflow problem during periods of precipitation. Assuming this
mass of TSS was uniformly di-scharged over the year,- -effluent- quality-
would more closely approximate that shown in Table 2.
TABLE 2. Comparison of Reported Versus Projected Effluent Quality
For Plant 1
EFFLUENT QUALITY
BODS
TSS,
PARAMETER
, mg/L
mg/L
REPORTED
17
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CALCULATED
71
136
Based on the sludge accountability analysis, it appeared that factors
other than the I/A facilities needed to be carefully scrutinized.
The unit process potential capacity graph was completed, as shown in
Figure 2, as were the individual interviews with the treatment plant
staff, the City administrators and the facility design engineer. Sup-
plemental information was obtained from the aeration system manufacturer
by telephone. Design, operational, maintenance and administrative fac-
tors potentially limiting facility performance were next identified and
ranked by the CPE team. "A" factors were felt to have a major impact
on performance on a continuous basis, while "B" factors were felt to
have either a minor impact on a continuous basis or a major impact on an
intermittent basis. The twelve factors identified as potentially limit-
ing facility performance, in descending order of importance, are dis-
cussed below.
Factor A-l: Sludge Dewatering— The conventional sand drying beds were
found to have an assessed capacity equivalent to an influent flow rate
of 568 nrVday (0.15 mgd), based on year-round utilization of the beds.
Without alternatives or additional facilities to overcome this sludge
dewatering limitation, it was projected that the facility could not be
expected to meet its NPDES permit requirements, even at current flows.
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Factor A-2: Aeration System— The I/A-funded aeration system was found
to have an estimated capacity equivalent to 2,460 nrVday (0.65 mgd) at
present organic 'loadings^- Supplemental aeration would -be required.-!©
properly treat the wastewater when the daily influent flow exceeded this
value.
Factor A-3: Sludge Wasting Capability— The I/A-funded 54 m3 (14,200
gal.) waste sludge holding tank was estimated to have a capacity equiva-
lent to an influent flow rate of about 1,325 nr/day (0.35 mgd). Capac-
ity of this fill-and-draw system was based on the mass of MLSS that
could be concentrated and stored in the tank during an eight-hour work
day. Due to system design and operation, the source of waste sludge had
to be the MLSS in the aeration tank, and not return sludge from the
secondary clarifier. Without adequate removal of excess sludge solids
from the treatment plant, it was felt that NPDES permit limits would
continue to be violated.
Factor A-4: Bond Indebtedness— Over 50 percent of the plant's budget
was allocated to bond payment. In addition, there was essentially no
allocation in the budget for facility capital improvements. A number of
the performance limiting factors identified would require substantial
capital expenditure to correct, but the capital was not available.
Factor A-5: Performance Monitoring— Collection of effluent composite
samples appeared to have been biased, since it did not include days on
which precipitation occurred. Data from days when samples were col-
lected indicated adequate removal of pollutants except for nitrogen
components. Since monitoring data was not indicative of plant per-
formance, the plant staff had no incentive to change operating condi-
tions or strategies. A review of operational control parameters indi-
cated that a number of changes were warranted to effect better effluent
quality.
Factor A-6: Operator Application of Concepts and Testing to Process
Control— The operators had received formal "classroom" training, but
seemed to have a difficult time applying activated sludge process
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control parameters to their own facility. This lack of understanding
was especially apparent in the area of adequate mass control in the
activated sludge portion of the plant. -•• •
Factor A-7: Technical Guidance— The plant staff sought technical
guidance from three primary sources: manufacturer's literature, the
facility's 0 & M Manual, and the operator of a neighboring community's
trickling filter secondary treatment plant. Information contained in
these sources often conflicted and often was not appropriate for the
time dependent variables that occur in biological systems. Long term
on-site training could be utilized to overcome this factor.
Factor B-l: Administrative Policies— The plant administrators devoted
essentially all of their time and effort to bond indebtedness issues,
development of budgets, insuring the prompt connection of users to the
collection system, and pursuing corrective actions for claimed treatment
plant unit process failures. Although the above were acknowledged as
being important, primary focus of the administrators should have been
assurance that the treatment plant was in continuous compliance with its
NPDES permit.
Factor B-2: Number of Staff— Current plant staffing was judged to be
adequate in all areas except sludge dewatering; where it was estimated
to be marginal. If the amount of sludge projected to be produced at
current loadings were to be adequately handled it was felt that addi-
tional staff would be required to dewater the anticipated sludge quan-
tity.
Factor B-3: Plant Inoperability Due to Weather— Abnormally cold
weather, coupled with low night-time wastewater flow rates, caused the
i
secondary clarifier to freeze up during the initial year of operation.
Normal weather patterns, coupled with increased wastewater flow rates as
a result of completion of trunk sewage lines, should negate this problem
in future years.
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Factor B-4: Inflow— Peak flow to the plant was reported to be 7,949
m^/day (2.1 mgd) which exceeded the design peak day flow. To minimize
system washout because, of stormwater inflow, improvements must be made
to the collection system.
Factor B-5: Process Controllability— The secondary clarifier was
designed to operate without return sludge pumps. This clarification
system worked, but positive control of return sludge rates could not be
effected, which was felt to yield less-than-optimum process control.
The results of the CPE as applied to Facility 1 indicated a variety of
results. The claimed aeration failure *was confirmed while the claim
associated with the secondary clarifier was deemed inappropriate. The
primary reason for performance problems was determined to be the sludge
dewatering capacity (sand drying beds). Integral to this was the
limited capacity of the I/A-funded waste sludge holding tank, a failure
not claimed by the City.
In summary, twelve factors were identified as potentially limiting the
performance of this facility. The comprehensive approach of the CPE
efforts was necessary to identify these multiple factors. A clear find-
ing of the failure of the I/A technology was not indicated and a follow-
up CCP to systematically address the factors identified was deemed war-
ranted. Findings did indicate that at current loadings and without
major modification to the I/A facilities the plant could be expected to
be in compliance if an alternative ultimate sludge disposal method could
be utilized (i.e., sludge hauling to a land disposal site). However,
unless all twelve factors are addressed and corrected, NPDES permit
compliance could not be expected as plant flows increased above present
levels.
Site Visit 2
Staff at Facility 2 claimed their I/A-funded aeration system was consum-
ing excessive power and were seeking relief from excessive power costs
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associated with this equipment. The conduct of a CPE identified the
following performance limiting factors and their level of impact.
Factor A-l: Aeration equipment.
Factor B-l: Sludge holding capacity during the winter.
Factor B-2: Operator application of concepts and testing to
process control.
The conclusion of the CPE activities was that claimed failure of the I/A
technology was justified, as evidenced by the aeration system being
noted as the highest ranking factor. The two other factors identified
also had a detrimental effect on plant performance and action to correct
these factors was recommended.
In Facility 2, the CPE more clearly indicated the failure of the I/A
technology. In addition, the comprehensive nature of the evaluation
also identified factors that degraded plant performance but were not
related to the I/A technology.
Site Visit 3
Facility 3 was designed to treat combined municipal and Industrial
wastewater. An innovative secondary treatment system was installed in
the existing activated sludge facility to allow treatment of wastewater
that varied substantially in strength and to allow removal of color from
the wastewater being treated. The City claimed that operation of the
I/A-funded system caused two failures within the plant. First, the sys-
tem allowed secondary sludge solids to settle in the aeration basins;
second, the system was causing massive scum formation to occur on the
final clarifiers. As a consequence, the Gity was pursuing 100% M/R
funding for an aeration system which would provide better aeration basin
mixing and for secondary clarifier scum removal equipment.
i
The CPE efforts identified the following potential performance limiting
factors in order of severity.
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Factor A-l: The I/A technology.
Factor A-2: Administrative policies.
Factor A-3: Sludge treatment/ultimate disposal.
Factor A-4: Operator application of concepts and testing to
process control.
Factor B-l: Process controllability.
Factor B-2: Aeration system.
Factor B-3: Industrial loading.
The I/A-funded technology produced a poorer effluent quality than would
result from conventional activated sludge treatment (Factor A-l). An
administrative policy of operating the I/A-funded system, even though
the operation resulted in NPDES permit violations, was in effect at the
facility (Factor A-2). The sludge digestion process yielded a poorly
stabilized sludge; the disposal of which was to be limited by more
stringent regulations in the near future (Factor A-3). Staff operators
were not utilizing daily field measurements and analytical results to
optimize a number of the plant's unit processes (Factor A-4). Valving
and piping did not allow for equal distribution of loads to parallel
treatment trains. In addition, a majority of the flow rate monitoring
equipment was either out of calibration or inoperative (Factor B-l).
Even with conventional activated sludge operation, the mixing provided
by the existing aeration equipment was deemed limiting (Factor B-2).
Shock industrial loads were felt to have the potential for plant upsets,
even though none had occurred over the recent past (Factor B-3).
With respect to the claimed failures, the CPE team found the aeration
system mixing capacity to be limiting. The claim associated with scum
formation was not felt to be appropriate; scum formed because of
hydraulic conditions between the aeration tanks and the secondary clari-
t
fiers, which resulted in massive levels of air entrainment.
i
The CPE effort identified the I/A technology as the highest ranking fac-
tor limiting performance at Facility 3. However, numerous other factors
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were identified. It was projected that addressing the other factors
during the systematic approach of a CCP would have allowed compliance
with NPDES .permit criteria to be achieved. It was-f-eLt--thati.-the- claorii^
provided by the listing of the multiple factors limiting performance
provided much needed insight into the complex plant performance problem.
Site Visit A
Designers of Facility 4, because of changes in the NPDES 'permit,
selected an innovative process for the achievement of wastewater
nitrification within the facility's existing aeration basins. The City
claimed that operation of the I/A-funded process resulted in two fail-
ures. The first was NPDES permit violations for selected inorganics;
the second was an excessive rate of corrosion to certain pieces of
treatment plant equipment. A 100% M/R grant request was being pursued
to rectify these claimed failures. ,
The CPE yielded the following potential performance limiting factors in
order of severity:
Factor A-l: The I/A technology.
Factor A-2: Industrial loading.
Factor B-l: Operator application of concepts and testing to
process control.
Factor B-2: Flow proportioning to units.
Factor B-3: Inflow.
The I/A-funded system was ineffective in removing inorganics from the
wastewater, a function which it was designed to accomplish (A-l). A
review of treatment plant influent characteristics showed abnormally
high concentrations of selected inorganics, which indicated the lack of
a fully implemented pretreatment program. These high influent concen-
trations were felt to contribute to effluent quality excursions (A-2).
Normal operational parameters were measured by the plant staff, but
utilization of the amassed information to optimize the performance of
the facility appeared to be lacking in certain areas (B-l). Equal
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flow/mass distribution to parallel unit processes was not being achieved
at the plant (B-2). Due to stormwater inflow, recorded peak flow rates
• had exceeded by a factor of-four the average daily--flew--design- value*
When such high rates occurred, unit processes were bypassed, which
resulted in the discharge of partially treated wastewater (B-3).
The CPE results indicated that the I/A-funded system was contributory to
the two claimed failures. However, other factors also contributed to
limiting system performance. Implementation of a CCP to address the
Identified factors exclusive of the I/A technology would have led to
improved performance. As with Facility 3, the CPE provided much clarity
to the complex performance problem at this facility.
Site Visit 5
An I/A-funded process to effect an effluent total phosphorus concentra-
tion of 1.0 mg/L was utilized at Facility 5. The City claimed that the
process failed to yield an effluent phosphorus of such quality and was
pursuing alternatives to meet their NPDES permit limitation for that
parameter.
The CPE team identified the following potential performance limiting
factors at this facility:
Factor A-l: Application of concepts and testing to process
control.
Factor A-2: Industrial loading.
Factor B-l: Process return streams.
Factor B-3: Flow proportioning to units.
Factor B-4: Administrative policies.
A review of operational control parameters utilized for most of the unit
processes at the plant indicated operational strategies which were felt
to inhibit the achievement of optimum performance (A-l). Influent total
phosphorus concentrations ranged from 8 to 27 mg/L on a daily composite
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basis. This range was felt to contribute to effluent quality variabil-
ity (A-2). Return streams from certain ancillary unit processes con-
-tributed.. measurable-mass ,.loadings of~BOD5>. TSS and total phosphorus to
the plant's mainstream major unit processes, which impacted overall sys-
tem performance (B-l). There was inadequate mixing in the activated
sludge aeration tanks to keep all of the MLSS in suspension and, as
such, capacity of this system was diminished (B-2). Return secondary
sludge solids could not consistently be distributed equally between par-
allel activated sludge treatment trains (B-3). Shift operators were not
involved in establishing operation control parameters set-points; the
plant superintendent made all process decisions on his own (B-4).
i
The CPE results could not be used to confirm the claimed failure of the
I/A-funded phosphorus removal system. As such, funding of a 100% M/R
grant was not clearly indicated. Other factors were identified as
involved in the less-than-optimum performance of this process. A CCP to
address the identified factors was recommended to utilize the projected
capacity of the existing treatment processes.
DISCUSSION OF RESULTS
Five facilities which had claimed failure of their I/A technologies were
evaluated using the CPE portion of the CCP approach. Although the eval-
uations had many facets, the main objective was the assessment of the
CPE for evaluation of poorly performing I/A technologies. Of particular
interest was the ability of the CPE to meet the requirements of the CG-
85 guidance document for a performance evaluation report prior to
approval of a 100% M/R grant. Relative to these requirements, it was
demonstrated that the CPE could be used to describe the claimed I/A
technology failure; evaluate the facility's current operational, mainte-
nance and administrative programs; assess system treatment capacity
relative to current and design loadings; indicate design/ construction
deficiencies; and identify design, operational, maintenance and/or
administrative factors limiting current system performance.
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The major unit process evaluation, as outlined in the EPA Handbook^',
was also modified, since I/A technologies are not included in the pub-
lished major unit process evaluation forms. The-•I/A---an-i-t processes-must
be evaluated based on experience gained working with other processes and
by analyzing available plant operating data.
Additionally, the CPE did not provide for a quality assurance review of
laboratory data, but did allow some assessment of data to occur through
use of comparisons of projected versus actual loadings and through the
use of system mass balances. The CPE approach did not provide for an
analysis of equipment warranties, but did provide for an evaluation of
equipment performance, at least as it related to current plant loadings.
The CPE evaluations did not include an evaluation of process warranties
or performance guarantees, nor did they assess blame for a claimed fail-
ure, address issues of negligence, provide specific recommendations to
correct identified failures, or ascertain the facility's eligibility for
100% M/R grant funding. These latter activities must be resolved by the
municipality, the State regulatory agency, and the U.S. EPA.
The limitations described did not preclude the value of the CPE in
assessing facilities with claimed failures of their I/A technologies.
The CPE provided a detailed prioritized list of the factors limiting the
facilities performance. Performance in this context was the overall
performance of the plant as it related to its design objective of meet-
ing certain water quality standards, and not performance solely of the
I/A technology. As shown in the case studies, the majority of factors
identified were extraneous to the I/A technology, and many had signifi-
cant impact on facility performance. The findings indicated whether M/R
funding was clearly established or whether a comprehensive program to
address multiple factors (CCP) was necessary prior to or during activi-
ties to ultimately achieve the desired consistent performance and/or
capability. It was concluded that the CPE allowed insight into a typi-
cally complex situation and provided direction for follow-up action that
could not have been accomplished with a less thorough effort. It was
concluded that the clarity provided by the approach was the necessary
first step to assessment of any 100% M/R request.
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SUMMARY
The CPE procedure is a valuable tool for assessing claimed failures of
I/A-funded technologies since it allows a comprehensive evaluation of
system deficiencies. Utilization of the procedure at the five reported
facilities often indicated deficiencies other than the innovative facil-
ity design. These findings had a direct effect on priorities for pursu-
ing corrective actions. The CPE did not always result in a clear direc-
tion for the implementation of a 100% M/R grant, but the approach was
very effective for evaluating the complex set of circumstances surround-
ing a claimed failure of an I/A technology. Because of these benefits,
the CPE evaluation should be considered for inclusion as an integral
part of the activities implemented to meet the regulatory requirements
for assessing the need for a 100% M/R grant.
REFERENCES
1. Construction Grants - 1985: Municipal Wastewater Treatment, U.S.
Environmental Protection Agency, Office of Water Program Opera-
tions, EPA Report No. 430/9-84-004, July 1984.
2. Hegg, B.A., J.R. Schultz, and K.L. Rakness, EPA Handbook:
"Improving POTW Performance Using the Composite Correction
Approach," U.S. EPA Center for Environmental Research Information,
EPA Report No. 625/6-84-008, October 1984.
"Although the research described in this article has been funded wholly or .
in oart by the United States Environmental Protection Agency through
Contract 68-03-1821 to James -M. Montgomery Engineers, Inc., it has not
been subjected to Agency review and therefore, does'not necessarily reflect
the views of the Agency and no official endorsement should be inferred.
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TECHNICAL REPORT DATA
(fti-ase read [iiunictiuns on lite reverse before completing)
i. REPORT NO.
2.
3. RECIPIENT'S ACCESSIG.VNO.
•t. TITLE AND SUBTITLE
5. REPORT DATE
Assessment of I/A Facilities Seeking 100% Modification/
Replacement Funding - Case Histories
6. PERFORMING ORGANIZATION CODE
7. AUTHOR1S)
Arthur J. Condren, Bob A. Hegg, Jon H. Bender,
Madan L. Arora
8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME ANO ADDRESS '
1. & 4. James M. Montgomery Engineers, Inc.
Pasadena, CA 91109-7009
2. Process Applications 3. U.S. EPA, WERL
Fort Collins, CO 80525 Cincinnati, OH 45268
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
68-03-1821
12. SPONSORING AGENCY NAME AND ADDRESS . •
Water Engineering Research Laboratory-Cincinnati, OH
Office of Research and Development
U.S. Environmental Protection Agency
Cincinnati, OH 45268 • '
13. TYPE OF REPORT AND PERIOD COVERED
Journal Article
14. SPONSORING AGENCY CODE
EPA/600/14
15' P*!*"ject"Officer?5 Jon Bender (513)569-7620. Presented at WPCF 59th Annual Conference
Los AngeleS, CA, October 6-9, 1986. Submitted to Journal Water Pollution Control
dft
lion
16,
Before U.S. EPA can pay 100 percent" of-the costs of modification or
replacement (100% M/R) of any I/A process which failed to meet their design
performance specifications, a determination must be made that the I/A portion
caused the failure or has significantly increased expenditures at the facility
and that the failure is not attributable to negligence. . The U.S. EPA also
developed the composite correcton program (CCP) approach which identifies the
unique combination of factors preventing compliance at a particular POTW. As
such, the CCP approach was felt to be well suited to meet certain requirements
for the determination prior to the awarding a 100% M/R Grant.
Five POTW's that had claimed failure of installed innovative technologies
were evaluated using the CCP approach. Multiple factors limiting performance
were identified at each POTW. The factors often included deficiencies not
related to the M/R grant request. These findings demonstrated that the CCP
approach was a viable and necessary first step in implementing solutions for
facilities requesting 100% M/R funding.
17.
KEY WORDS ANO DOCUMENT ANALYSIS
a.
DESCRIPTORS
b.lOENTIFIERS/CPSN ENDED TERMS C. COSATI Field/Group
13. OISTHI8UTION5TATEMENT
RELEASE TO PUBLIC
19. SECURITY CLASS (TliaReport)
UNCLASSIFIED
21. NO. Of PAGES
20. SECURITY CLASS (Thispage)
UNCLASSIFIED
22. PRICE
EPA Form 2220-1 (3-73)
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