&EPA
United States
Environmental Protection
Agency
Office of Water
Office of Human
Resources Management
December 1987
905R87107
Assessment of Human
Resource Needs
Region V
Water Toxics
Control Program
-------
FINAL REPORT
WATER TOXICS CONTROL
HUMAN RESOURCES PLANNING PROJECT
December, 1987
EPA Contract 68-01-7281
Order No. 7
AMERICAN MANAGEMENT SYSTEMS, INC.
1777 N. Kent Street
Arlington, VA 22209
-------
TABLE OF CONTENTS
PAGE
EXECUTIVE SUMMARY i
I. INTROniJCTION I- 1
A. Background I- 1
R. Overview of Renort I- 3
C. Methodology I- 5
II. HUMAN RESOURCE PLANNING II- 1
A. Overview II- 1
R. Position/Occupational Series Mix II- 4
C. Tasks/Activities in Rank Order (by Division) II- 8
n. Post-BAT Tasks/Activities, by Positions/Occunational
Series 11-10
E. Future Critical Tasks Rv Position 11-10
III. HUMAN RESOURCE STRATEGIES Ill- 1
A. Overview III- 1
R. Region V Staff Members' Knowledges and Abilities Ill- 2
C. Program-wide Strategies to Address Knowledge and Ability Gaps. III-22
LIST OF EXHIBITS
EXHIBIT 1 Number of Respondents by Division and Operational Unit I- R
EXHIBIT 2 Number of Respondents by Division and Position II- 2
EXHIBIT 3 Number of Respondents by Division and Occupational
Series II- 3
EXHIBIT 4 Region V Managers' Selection of "Best Fit" Position/
Occupational Series Mix II- 6
EXHIBIT 5 Rank Ordered Key Tasks/Activities by Amount of Time
Soent on Each II- 9
EXHIBIT 6 Region V Managers' Selection of Position/Critical Task/
Activity Mix "Best Fit" IT-11
EXHIBIT 7 High/Low Ratings of All Abilities by Position III-ll
-------
TABLE OF CONTENTS (Cont.)
PAGE
EXHIBIT R High/Low Ratings of All Abilities By Position IIT-12
EXHIBIT 9 High/Low Ratings of All Abilities By Position III43
EXHIBIT 10 High/Low Rankings, Bv Position, For Both Knowledges
and Abilities Ill-15
EXHIBIT 11 High/Low Ratings of Key Knowledges BV Position 111-25
EXHIBIT 12 High/Low Ratings of Key Abilities By Position Ill-26
APPENDICES
APPENDIX A SUPPORTING DOCUMENTATION FOR DATA ANALYSIS
APPENDIX A- 1 Academic Degrees By Division and Field of Study A- 1
APPENDIX A- 2 Numbers of Respondents by Division and Previous
Occupational Series A- 2
APPENDIX A- 3 Academic Degrees By Position and Field of Study A- 3
APPENDIX A- 4 Number of Respondents By Position and Occupational
Series A- 5
APPENDIX A- 5 Weighted Ranking of Critical Tasks/Activities By
Time Soent (Bv Division) A- fi
APPENDIX A- 6 Number of Staff Bv Position and Critical
Task/Activitv A- 7
APPENDIX A- 7 Number of Staff By Occupational Series and Critical
Task/Activity A- 8
APPENDIX A- 8 Number of Respondents by Knowledge/Ability in
Critical Task/Activity A- 9
APPENDIX A- 9 Number of Respondents by Ability Level and Critical
Task/Activity ". A-ll
APPENDIX A-10 Respondents' Evaluation of Their Developmental
Experiences Related to Present Work A-13
APPENDIX B Documentation of Process - Region V B- 1
APPENDIX C Documentation of Process - Michigan C- 1
APPENDIX D Trends and Changes D- 1
APPENDIX E Phase III/IV Survey Instrument E- 1
APPENDIX F Phase II Managerial Interview Guide F- 1
APPENDIX G Index to Know!edge/Ability Codes R -1
-------
EXECUTIVE SUMMARY
This report summarizes the results of a study which was conducted in
Region V in order to review and define Regional water toxics control program
work requirements, and to determine the quantity and types of skills needed to
implement these requirements in the future. The study has been conducted by
American Management Systems, Inc. (AMS) at the request of the Office of Water
Regulations and Standards (OURS) and the Office of Human Resources Management
(OHRM). It is the second in a series of similar studies which were initiated
to address the concerns which Water Program managers raised at the May, 1985
Integrated Water Quality Management meeting regarding State and Federal
staffing requirements for fully implementing water quality-based toxics
control programs.
This study was conducted in the following sequence of activities:
• Document Region V's current processes for controlling water
toxicity;
• Define program activities and identify likely program trends
and future human resource needs which Region V managers
predict could result from those trends;
t Define Region V's current and future workforce characteristics
to fully implement post-BAT toxics management processes; and
• Provide strategies for ensuring that Region V has the proper
quality of staff to execute its future program needs.
Findings Re General Program Trends
The Region V staff is fairly experienced. Only 6% of the respondents have
been in their positions six months or less. One-third of the staff have been
in the same position for over five years, and 65% (84) have been in the same
position for two years or more. It is also significant to note that very
experienced staff (i-e-» with two or more years of experience) cluster in
several key occupations — Section Chief, Permit Writer, Compliance Engineer,
Ambient Monitoring Specialist, and Water Quality specialist.
The occupational series distribution of the respondents reflects a heavy
emphasis on environmental science and engineering, with Environmental
Engineers accounting for 36%, Environmental Protection Specialists, 21%, and
Environmental Scientists, 12%. These three occupations represent about 70% of
the total sample.
A total of 191 degrees were claimed by respondents to the survey, over a
range of 15 different academic fields (Appendix A-l). Yet academic degrees in
engineering technology (31) accounted for over 20% of the total, followed by
degrees in the biological sciences, 27 (14%).
-------
Seven of seventeen section chiefs, who typically function as first line
managers, are environmental engineers, with another four sections chiefs in
the chemist occupational series. As the Region continues to build and expand
its capabilities in toxicity-based approaches, management may want to consider
providing training in toxicology, biology and other related sciences. In
addition, the Region could target future line management recruitment actions
on candidates with disciplines in these fields.
The WD and ESD staff members who responded to the survey focus their
attention on different, but complementary tasks/activities, reflecting the
mutual dependency of each Division in meeting the goals of Region V's water
toxics control strategies. The WD respondents ranked "Identifying Toxic
problems" first as the task/activity with which they are most involved,
followed by "Reviewing compliance evaluation inspections" and "Compliance
monitoring" activities. ESD respondents ranked "Review" bioaccumulation
studies" first, followed by "Review of stream data" and "Conducting sediment
analyses".
During Phase II of this study, Region V managers were asked to identify
those tasks/activities which are likely to be critical to positions in the
post-BAT toxics water control program over the next three years. The key
points made by Region V managers with respect to this issue are:
t Four positions are forecast as being likely to experience a
significant amount of growth in their areas of activity over
the course of the next three years:
-- Standards Coordinators are predicted to have eight
activities added to the two they are now primarily
involved with. These new responsibilities will include
such things as conducting bioaccumulation studies, and
fate and transport modeling;
— Permit Writers are likely to see an expansion of their
current role (which is primarily one of identifying toxic
problems, establishing permit standards, and developing
water quality limits) to include such new activities as
conducting bioaccumulation and sediment studies, and fate
and transport modeling;
— Water Quality Modelers could see a similar expansion of
their duties in the areas of bioaccumulation and sediment
studies, and fate and transport modeling; and, finally
— Ambient Monitoring Specialists, Water Quality
Specialists/Biologists and Compliance Engineers may have
their areas of responsibility expanded to include the
review and development of water quality limits, and the
conduct of sediment studies and toxicity tests.
• Current staff members are reasonably well placed to meet the
future demands of positions such as Compliance Monitoring
n
-------
Specialist, Water Quality Specialist/Biologist, and
Para-Technical Compliance Specialist. As we will see in the
next chapter, while the match between projected future areas
of activity and current tasks is strong for both Water Quality
Specialist/Biologists and Para-Technical Compliance Special-
ists, their self-assessment of their knowledge and ability
levels in those areas which managers predicted would be
critical to meeting these new responsibilities were the lowest
of all respondents.
Findings Re Key Water Program Positions
For the position of Compliance Engineer, the seventeen respondents who
currently occupy the position assessed their levels of expertise as high for
most of the knowledges and abilities which Region V managers identified as
being critical to performing that position's key tasks. The members of this
group rated themselves as having low levels of expertise in two key knowledges
— those of the Clean Water Act/EPA policies re Toxics, and Legal Issues re
Toxics. Given the nature of this position's duties, it is also useful to note
that the sample's self-assessment of expertise was "mixed" (i.e., half the
sample rated themselves as "high" and half the sample rated themselves as
"low") in the knowledges of environmental engineering re treatment processes,
and facility design and operation.
Region V managers predict that the duties of the Water Quality Specialist/
Biologist position will expand to include developing/reviewing water quality
standards, setting/reviewing water quality-based permit limits, and reviewing
the results of bioaccumulation studies. Of the key knowledges and abilities
Region V managers identified as critical for this position in the future,
eleven respondents who currently occupy this position rated themselves as
strong in their knowledge of chemical, biological and physical principles, but
weak in their knowledge of:
t environmental engineering re treatment processes;
• toxic aquatic and human health effects; and
• toxics modeling.
They were also low, as a group, in their ability to conduct treatment facility
inspections and to serve as technical/expert witnesses.
While there are a number of possible techniques to enhancing the expertise
of this group in the above knowledges/abilities, one relatively immediate
option available to Region V management is to have the current incumbents of
the Pre-Treatment Coordinator and Water Quality Standards positions act as
"consultants" to the Water Quality Specialists/Biologists on issues relating
to toxic aquatic and human health effects and toxics modeling, since the
incumbents of the Pre-Treatment Coordinator and Water Quality Standards
positions assessed their levels of expertise in these two knowledges as
"high". In addition, it would also be advisable for Region V management to
provide additional training to staff members in toxic health effects,
-------
particularly for those staff members who occupy positions where gaps in that
knowledge have been identified (e.g., Permit Writers, Compliance Monitoring
Specialists, Compliance Engineers, Water Quality Specialists/Biologists, and
Paratechnical Compliance Specialists).
The Water Quality Modeler position, while not reporting any "LOW" ratings
for its key knowledges or abilities, did show "MIXED" ratings for fourteen of
the fifteen identified knowledges/abilities. These results are particularly
worrisome in view of Region V managers' prediction (in the Phase II survey)
that this position's duties would have eleven new tasks added to it in the
future. Since the occupants of both the Standards Coordinator and
Pre-Treatment Coordinator positions assessed themselves as "HIGH" in seven of
the eight key knowledges where the results for Water Quality Modeler
incumbents were "MIXED", Region V management should consider the feasibility
of:
• Detailing Water Quality Modeler staff to the Pre-Treatment or
Standards Coordinator positions to improve the affected
skills;
• Using the Pre-Treatment Coordinator or Standards Coordinators
as "advisors/consultants" to the Water Quality Modelers on
complex issues where the former have expertise; and
• Having the Pre-Treatment Coordinator and/or Standards
Coordinators develop some in-house training programs to
enhance Water Quality Modelers' expertise in the most critical
knowledges and abilities.
The occupants of the Ambient Monitoring Specialist position rated
themselves as "HIGH" in all critical knowledges and abilities that Region V
managers cited, except the knowledge of toxics modeling and ability to
conduct treatment facility inspections. Since these latter two are areas
which are important to the evolving role of the ambient monitoring specialist,
Region V should consider how best to supplement their staff members' level of
expertise in these areas. Since no group of respondents rated themselves as
"HIGH" in toxics modeling, this may be an area where a targeted training
program (using university or contractor resources) would be beneficial. It is
also possible that Region V staff members in other programs possess sufficient
expertise in this area to assist in developing an in-house training program in
toxics modeling. Depending on Region V management's assessment of the degree
of demand for this knowledge, a specialized recruitment effort to hire an
expert in this field should also be considered.
The findings for the incumbents of the Compliance Monitoring Specialist
and Pre-Treatment Coordinator positions showed substantial strength in
virtually all of the key knowledges and abilities identified for these
positions. This is an important area of program strength for the Region, and
should also be utilized as a resource in buttressing areas of weakness in key
skills among the incumbents of other positions. The two areas where the
Compliance Monitoring Specialist incumbents noted some weakness were in their
knowledge of Clean Water Act/EPA policies re toxics and legal issues re
toxics. Both of these knowledges are amendable to targeted, in-house
training; and Region V management should move to address this -- particularly
-------
in the area of legal issues re toxics, since incumbents of four of the six
positions where this was identified as a key knowledge assessed themselves as
"LOW" in their level of expertise.
Finally, the findings for the positions of Para-Technical Compliance
Specialist and Permit Writer reveal numerous areas of weakness in key
knowledges and abilities. Given the nature of their position's duties, it is
especially noteworthy that incumbents assessed their expertise as "LOW" in the
knowledges and abilities re:
t environmental engineering re treatment processes;
• regulations re facility design and operations;
• knowledge of the Clean Water Act/EPA policies re toxics; and
• ability to conduct treatment facility inspections.
An examination of the overall results shows that these are areas of
weakness across most of the positions in the Water program. Incumbents of the
Permit Writer position appear to be weak in the same and/or similar knowledges
(e.g., wastewater treatment processes, regulations re facility design and
operation, and legal issues re toxics). In fact, the results of the survey
indicate that region V staff members assessed themselves as either "LOW" or
"MIXED" in four key knowledges across all positions requiring those
knowledges. They are:
• environmental engineering re treatment processes;
• regulations re facility design/operation;
• toxic water modeling; and
• legal issues re toxics.
Since the level of in-house expertise is uniformly low, the most likely
strategies for closing these "gaps" in key knowledges include:
• targeted recruitment efforts to acquire staff members with
expertise in treatment process technology and facility design/
operation, and toxic water modeling; and
• focused, in-house training in the knowledge of the legal
issues re toxics.
Given that expertise in the latter knowledge may reside in Agency staff from
other programs, the availability of those resources should be assessed, since
they would be the most cost-effective source of course designers/instructors
for this training program.
Strategies to Address Potential Knowledge/Ability Gaps
Region V has an experienced, dedicated staff with adequate or better
levels of expertise in most of the key knowledges and abilities for most of
its critical tasks. As it continues to implement the post-BAT toxics control
program, it is important that Region V management focuses on developing an
acceptable level of competency among its staff members in all critical
knowledges and abilities, and an appropriate amount of staffing depth for
-------
those positions whose duties are expected to see significant growth and/or
change as a result of the shifting programmatic emphasis.
There are a number of potentially useful techniques which Region V
management should consider, including:
• Training, which is a measure that is particularly suited to
enhancing staff members' capabilities in such areas as:
— Knowledge of EPA/state regulations;
— Knowledge of industrial processes;
— Knowledge of legal issues;
~ Knowledge of the Clean Water Act;
— Knowledge of human health effects; and
— Knowledge of toxics water modeling.
The methods for delivering this training can include such techniques as:
on-the-job training, classroom-based training offered by colleges,
universities, private-sector contractors, or the EPA Institute; workshops and
seminars to be developed by Region V staff members; and computer-based
training.
The Phase II and III surveys allowed managers and employees to identify
those tasks/activities for which additional training might be necessary and
helpful. Within the WD, staff seem most interested in additional training to
increase effective performance for identifying toxics problems and conducting
toxicity tests. ESD staff, on the other hand, are much more consistent in
their desire for additional training to increase effective performance across
all tasks/activities, while some respondents also desire additional training
to be prepared for new work assignments concerning POTW sludge analysis and
overall monitoring strategies due to the increasing emphasis on biomonitoring
activities within Region V's toxics management control strategies.
Some of this training can probably be best performed by Region V staff
members with demonstrated expertise in a given area. Possible approaches for
developing and delivering the requested training include:
— Participation in developing and delivering courses via the
EPA Institute;
— Structuring and implementing focused "on-the-job" training
in areas where application of specific technologies is
highly dependent on specific situational factors (e.g.,
testing methods for toxics, such as bioaccumulation
studies, toxics water modeling, etc.); and
-- Developing seminars using in-house staff to keep Region V
staff members current with trends in program policies,
Clean Water Act requirements, legal issues and procedures.
These are all areas where gaps were found consistently,
whether data was arrayed against positions, tasks, or
simply the entire pool of respondents in aggregate.
-------
Job Rotation Is another effective technique for developing
staff member expertise in areas where it is critically weak,
while offering the additional benefit of broadening staff
members' perspective vis-a-vis the various roles and
responsibilities of positions within Region V's water toxics
program.
Region V has shown a willingness to detail staff members to
positions in state agencies as a means of technology transfer
to those organizations which are assuming increasing
responsibility for water toxics control. This technique is
viewed by Region V management as having been fairly successful
in accomplishing the technology transfer objective, but it was
not reported to have had measureable impact on improving
competency in key knowledges and abilities.
For the latter objective to be met more effectively, it is
preferable to structure a job rotation program which has the
explicit objective of enhancing competency in a particular
skill, or conversely, buttressing competency in a key area
where the current incumbents of the position are noticeably
weak. To accomplish this, possible approaches include:
-- Detailing staff members who are weak in a given knowledge
or ability to position whose members are very strong in
those specific knowledges or abilities; and/or
— Detailing a staff member with an advanced level of
expertise in a knowledge or ability into a position which
is weak in the same essential knowledge.
Since Region V staff members appear to be strong in their
levels of expertise for four of the nine positions regarding
future skill needs, job rotation should be considered as an
option for those two positions where significant weaknesses
appear to exist. Furthermore, that rotation should be of weak
staff members to positions whose incumbents are strong in the
relevant knowledges and abilities, since coverage in the two
positions where that appears to be the case (i.e., strong
incumbents) is very limited (e.g., only one and two incumbents
in those two positions, respectively).
Thus, it would appear to make more sense to detail Permit
Writers (whose skills are assessed as weak) to the
Pre-Treatment Coordinator position (whose skills are assessed
as strong), since they share identical sets of "key
knowledges", and virtually identical sets of "key abilities".
Water Quality Specialist/Biologist rotation into the Standards
Coordinator position might also provide opportunities to
enhance specific "key knowledges" where the former group is
noticeably weak. Finally, Region V management should consider
a rotation of Para-technical Compliance Specialists into
either a Compliance Monitoring Specialist or Compliance
Engineer slot, as long as there is a clear understanding that
-------
the role to be played by the "detailee" is one of "apprentice
to", not "substitute for", current occupants of those
positions as a means of developing the very weak skill levels
of the Para-Technical Compliance Specialists.
• Specialized recruitment is potentially an effective approach
to buttressing staff members competence in critical knowledges
and abilities where slots are available. It is typically most
appropriate when the nature of the target knowledge or ability
requires such a substantial amount of academic training and/or
professional expertise to acquire that it would be impractical
to attempt to bring current staff members up-to-speed in that
area. Possible knowledges where gaps exist, and which also
appear to meet the above criteria, are those of
physical/chemical and biological principals, human health
effects, industrial processes, and toxicology. Such a
strategy of specialized recruitment is particularly
appropriate, given the other conditions, when the Region has
an immediate need for skill in a certain area, and no
capability (however low) exists within the current staff; and
finally,
t Details of staff members from other areas of the Water
program, or from other related Region V programs (e.g., Ground
Water) where the detailees possess expertise in critical
knowledges or abilities, and where the use of what is
typically a "short-term" technique is warranted for
consideration. Examples of such cases include detailing an
expert in toxics modeling to a Water Quality Modeler position
to provide some training for the other incumbents of that
position. It would be equally appropriate to use staff member
"details" as a means of buttressing knowledge gaps in a
particular position while a targeted recruiting effort is
underway. The essential characteristics of this technique are
that it is inherently a short-term solution, and it presumes
that there are staff members in other program areas who
possess the knowledge or ability which is missing among
incumbents of the target positions.
-------
1-1
I. INTRODUCTION
A. Background
In May 1985, Water Program Managers from around the country gathered at
the Integrated Water Quality Management meeting and expressed their concern
about State and Federal staffing requirements for fully implementing water
quality-based toxics control programs. The Office of Water Regulations and
Standards (OWRS), in cooperation with the Office of Human Resources Management
(OHRM) and the Personnel Management Division (PMD) have initiated a series of
human resource planning studies designed to address these concerns. The
purpose of these studies is to review and define Regional water toxics control
program work requirements, and to determine the quantity and types of skills
needed to implement these requirements in the future.
The current effort in Region V, whose final results are summarized in
this report, is the second in the series of planning studies referred to
above. Region V was selected as the site for this study because of its
innovative approach to water toxics control problems, and because it is a good
example of a Region whose states have all been delegated NPDES authority.
The objectives of the Region V study have been accomplished through a
four-phase effort:
• Document Region V's current processes for controlling water
toxicity;
• Define program activities and identify likely program trends
and future human resource needs which Region V managers predict
could result from those trends;
• Define Region V's current and future workforce characteristics
to fully implement post-BAT toxics management processes; and
-------
1-2
• Provide strategies for ensuring that Region V has the proper
quality of staff to execute its future program needs.
Phase I focused on identifying Region V's current management processes for
overseeing State standards-to-permits processes for water toxics and Region V
initiated water toxics control functions. Key Region V managers and line
personnel were interviewed during this phase and provided information on all
related Region V activities.
In Phase II of this study, Region V managers defined the Region V
oversight programs key functions and tasks, identified specific knowledges,
skills, and abilities for future oversight activities to implement the Region
V oversight role. AMS conducted in-depth interviews with Region V managers to
verify current processes and identify future program trends and skills needs
to meet Regional oversight responsibilities.
Phase III of the study identified, through a staff survey, the current mix
of knowledge, skills and abilities (KSA) ' for Region V standards-to-permits
oversight responsibilities and defined which of those capabilities can be
applied to the future post-BAT toxics management processes.
Finally, Phase IV integrates the information from each of the previously
completed phases and identifies "gaps" between Region V's future resource
needs and Region V's currently available staff capabilities. The study team
also examined options such as training programs, staff allocation and
development policies and recruitment alternatives in defining possible human
resource strategies to ensure that Region V has a properly trained workforce
to implement oversight guidance in the years ahead.
Due to production problems of the employee survey, we were not able to
obtain adequate "skills"-related data.
-------
1-3
B. Overview of Report
This report presents the results of this final phase of the OWRS/OHRM
human resources data collection effort in Region V. As mentioned above, a
self-administered survey instrument was distributed to Region V staff and
management to collect data on existing knowledges and abilities to execute
post-BAT water toxics control processes. In order to determine the Region's
capacity to meet its water toxics control program needs with qualified
personnel, data were collected from 138 Region V staff members. Besides the
staff capabilities, the data also identifies the current staff positions and
occupational distributions. Specifically, this report will:
• Examine the present Region V staff position/occupational series
mix for post-BAT water quality toxics control tasks/activities;
• Analyze the current Region V staff members' mix of knowledges
and abilities for post-BAT water quality toxics control tasks/
- activities, and positions;
• Compare current Region V staff members' knowledges and abili-
ties for post-BAT water quality toxics control tasks/activiti.es
with future knowledge/ability needs identified by Region V
managers in the Phase II Report;
• Detail the job characteristics contributing to Region V staff
work requirements and performance levels, and;
• Identify alternative human resource management strategies for
Region V management to ensure successful implementation of
future post-BAT water toxics control processes.
This Report is divided into the following sections:
• Chapter I: Introduction. Describes the overall project
structure, presents the purpose of the Phase III/IV Report and
outlines the report's content;
-------
1-4
• Chapter II: Human Resource Planning. Examines Region V staff
members' occupational distribution (by current position and
occupational series), previous work experience, and academic
background. The analysis presented in this chapter compares
the current position/occupational series mix with the projected
position/occupational series mix defined by Region V managers
in Phase II of this project. As the post-BAT toxics control
process becomes fully implemented, changes in Region V task/
activity priorities are expected. This chapter also evaluates
the nature of these changes in the post-BAT tasks/activities as
identified by current Region V staff and managers;
• Chapter III: Human Resource Strategies. Region V's capability
to perform critical tasks/activities is dependent upon the
level of staff expertise. Successful implementation of Region
V post-BAT water toxics control programs will require shifting
priorities and tasks among various position/occupational
series. This chapter examines current staff knowledges and
abilities, by Division, position and task/activity. It also
compares the current Region V staff knowledges/abilities
distribution for tasks/activities with managers' perceptions of
the most effective knowledges/abilities distribution for future
post-BAT water toxics control tasks/activities and identifies
"gaps". This chapter also examines current Region V staff
members' developmental job experience and training levels to
determine the most effective methods for preparing current
Region V staff to meet future work requirements identified by
Region V managers. Finally, this chapter presents alternative
training strategies and staff developmental activities to close
"gaps" between future resource needs and current staff
capabilities.
-------
1-5
C. Methodology
The Phase III/IV project activities fall into two principal categories:
data collection and descriptive/comparative analyses. The sequence of tasks
for this phase of the project was as follows:
• Prepare an employee survey;
• Distribute survey to Region V Water Division and Environmental
Services Division staff;
• Conduct the necessary data analyses; and
• Prepare and submit the findings presented in this report.
The Phase III/IV project activities were organized into four primary
tasks:
Task 1. Preparing the Survey Instrument
The survey instrument was forwarded to Region V staff for self-
administration. The survey instrument was designed from the analysis
described in the project's Phase I and II Reports, the Region I Phase III
survey instrument and interviews with Headquarters and Region V WD and ESD
staff. Based on these efforts, project staff established Phase III/IV
information requirements and constructed a data collection instrument to
address those requirements. The objectives of the survey were:
t To document the current WD and ESD staff organizational
distribution, job characteristics and post-BAT water toxics
tasks/activities; and
• To determine the current WD and ESD knowledge and ability
levels for conducting post-BAT water toxics activities.
-------
1-6
The survey is highly structured, consisting of alternative choice and
fixed response questions. This approach was used to ensure greater data
consistency, and facilitate computational analysis. A few questions were
open-ended, in the hope of eliciting more spontaneous responses. The actual
survey was undertaken without direct supervision of project staff. Respondents
were urged to contact project staff if questions were not clearly specified.
Questions in the survey were organized into the following sections:
• Demographics of the interviewee, consisting of questions relat-
ing to a repondent's personal characteristics (e.g., current
position, academic background, previous work experience);
• Identification of the nature of the interviewee's participation
in post-BAT water toxics control tasks and activities;
.• Identification of the interviewee's knowledge and ability
levels for conducting post-BAT water toxics control tasks/
activities; and
• Discussion of training requirements for post-BAT tasks/
activities.
Task 2. Completing Region V Staff Questionnaires
Questionnaires were forwarded to Region V for distribution to Water
Division and Environmental Services Division staff. Completed questionnaires
were then mailed back to EPA Headquarters for project staff analyses.
Task 3. Conducting Data Analyses
A total of 242 survey guides were forwarded to Region V Headquarters. The
Water Division received 182 surveys, of which 98 (54%) were completed. The
Environmental Services Division staff completed 40 (67%) of the 60 surveys
received. Given the amount of data which was collected, it is reasonable to
-------
1-7
assume that it presents a reasonably accurate description of Region V's
current human resource trends. The majority of the analysis consists of
frequency distributions, and cross-tabulations of the data, providing an
inventory of Region V staff information for descriptive and comparative
analyses.
Task 4. Report Preparation
The interview results and data analyses have been incorporated into
narrative and tabular presentations.
Exhibit 1 presents the distribution of survey respondents. The Water
Quality Branch (31) and the Municipal Facilities Branch (33) account for 76%
of the Water Division (WO) respondents who identified an affiliation with a
specific Branch or Office. The Central Regional Laboratory's staff members
account for 35% of all Environmental Services Division (ESD) respondents.
-------
II-l
II. HUMAN RESOURCE PLANNING
A. Overview
The objective of this section of the report is to identify each current
Region V staff position and to describe the characteristics of each position.
The Phase II Report identified those occupations which senior Region V
managers expect to be of great importance in water toxics control activities
over the course of the next three years. This section will compare the
current Region V staff members' position and occupational series placements
with the managers' anticipated position/occupational series combinations, and
will present the results of several analyses of trends in key tasks/activities
and matches between the current mix of occupational series vs. projected
needs.
The distribution of respondents' positions, by Division, is presented in
Exhibit 2. The 29 respondents who identified their position's title as
"Other" comprise 21% of our total sample, followed by Permit Writers (13%),
Section Chiefs (12%), and Compliance Engineers (12%). Ambient Monitoring
Specialists and Compliance Monitoring Specialists are also fairly well
represented, (8%), relative to other positions. Within the Water Division
(WD), Permit Writers comprise the majority of our sample (17%), while
Compliance Engineers account for the majority (23%) of the Environmental
Services Division's (ESD) respondents.
The Region V staff is fairly experienced. Only 6% of the respondents have
been in their positions six months or less. One-third of the staff have been
in the same position for over five years, and 65% have been in the same
position for two years or more. It is also significant to note that very
experienced staff (i.e., with two or more years of experience) cluster in
several key occupations — Section Chief, Permit Writer, Compliance Engineer,
Ambient Monitoring Specialist, and Water Quality specialist.
The occupational series distribution of the respondents (Exhibit 3)
reflects a heavy emphasis on environmental science and engineering, with
Environmental Engineers accounting for 36%, Environmental Protection
Specialists, 21%, and Environmental Scientists, 12%. These three occupations
-------
11-2
EXHIBIT 2
Number of Respondents by Division and Position
POSITION
Division Director
Deputy Divison Director
Branch Chief
Section Chief
Pre-Treatment Coordinator
Standards Coordinator
Permit Writer
Water Quality Modeler
Compliance Monitoring
Specialist
Compliance Engineer
Ambient Monitoring Specialist
Water Quality Specialist/
Biologist
Para-Technical Compliance
Specialist
State Grants Coordinator
Other
TOTAL
WD
1
4
11
1
3
17
1
7
8
5
7
2
9
22
98
ESD
0
2
6
0
0
1
2
4
9
4
4
1
0
7
40
TOTAL
1
6
17
1
3
18
3
11
17
9
11
3
9
29
138
-------
II-3
EXHIBIT 3
NUMBER OF RESPONDENTS BY DIVISION AND OCCUPATIONAL SERIES
OCCUPATIONAL
SERIES
Administrative and Clerical
Specialist
Aquatic Biologist
Chemist
Chemical Engineer
Environmental Engineer
Environmental Protection
Specialist
Environmental Scientist
Environmental Life Scientist
General Biologist
Geologist
Grants Specialist
Microbiologist
Physical Scientist
Program Analyst
Physical Scientist (Student)
Other
TOTAL
WD
—
0
1
4
11
38
28
--
4
4
--
0
--
4
0
4
98
ESD
--
2
10
1
5
12
1
--
1
2
«
1
—
1
3
1
40
TOTAL
--
2
11
5
16
50
29
—
5
6
—
1
--
5
3
5
138
-------
II-4
represent almost 70% of the total sample. The basis for this distribution can
be better understood by examining the academic backgrounds of the survey
respondents. A total of 191 degrees were claimed by respondents to the
survey, over a range of 15 different academic fields (Appendix A-l). Yet,
academic degrees in engineering technology (31) accounted for over 20% of the
total, followed by degrees in the biological sciences, 27 (14%). A
substantial number of respondents, 38 (20%), identified "other" as the
academic field that best reflects their academic training. No staff member
appears to have an academic background in computer science. Region V managers
identified the use of computers and computer modeling as a major program
trend. The Region has indicated, however, that general computer support
services are provided through their Management Division. Finally, more than
half of all respondents (58%) held previous jobs in environmental
science/engineering fields (Appendix A-2).
A further breakdown of the data (Appendix A-3) pinpoints the distribution
of the engineering technology, and biological science degree-holders by
position. Seven engineering technology and two biological science degrees
were identified by the seventeen Section Chiefs in the survey. Of the
seventeen Compliance Engineers, eight hold at least a Bachelor's degree in
engineering technology. The eleven Compliance Monitoring Specialists
identified four degrees in engineering technology, and three (M.A.) degrees in
biological science, while the eighteen Permit Writers claimed six, and five,
respectively. The one Pre-treatment Coordinator in our survey possesses a
doctoral degree in engineering technology. Almost 50% of the survey
respondents hold at least one degree in engineering technology, while
approximately 63% hold a degree in the biological sciences. Thus, although a
greater number of engineering degree holders were identified, the lesser
number of biologial science degrees are more dispersed across the respondent
population.
B. Position/Occupational Series Mix
The Position/Occupational Series mix from the Region V survey response is
presented in Appendix A-4. A review of this data reveals that three
occupational series dominate the management level positions in the two
Divisions: environmental engineer, environmental protection specialist, and
-------
II-5
environmental scientist. These occupations also dominate the overall sample,
collectively accounting for 95 of 138 respondents. They are each distributed
across nine positions, thus accounting for the most widespread distribution
(among positions) of all occupational series.
It is also worth noting that seven of seventeen section chiefs, who
typically function as first line managers, are environmental engineers, with
another four section chiefs in the chemist occupational series. As the Region
continues to build and expand its capabilities in toxicity-based approaches,
management may want to consider providing training in toxicology, biology and
other related sciences. In addition, the Region could target future line
management recruitment actions on candidates with disciplines in these fields.
The Region V managers in the Phase II study were also asked to identify
the "best fit" between positions and occupational series, in order to meet the
challenges of post-BAT water toxics control activities over the next three
years. Exhibit 4 presents the managers' identification of "best fit" between
occupational series and post-BAT positions, arrayed against the staff's
current positions/occupational series combinations. An 'X1 in the "MANAGERS"
column of this table reflects a specification by more than 50% of the managers
responding in the Phase II survey that a particular position/occupational
series combination will be relevant for post-BAT water toxics activities over
the next three years. The actual percentage of staff respondents who
currently occupy the various position/occupational series combinations is
presented in the column labeled "STAFF" in this table.
The managers selected the occupational series category "Environmental
Engineer" as providing a "best fit" for six future positions -
• Pre-treatment Coordinator;
• Permit Writer;
t Water Quality Modeler;
-------
II-6
fc £
x u
UJ CD
fe
Z
F;
U.
1V10.L
JOjBuipuooo
isijBioeds
Buuouuon
lueiqwv
jeeuiBug
•3UEI|duiOQ
IsciBioedg
8uuoiiu
-------
II-7
• Compliance Monitoring Specialist;
t Compliance Engineer; and
• Ambient Monitoring Specialist.
The current staff placement seems to reflect this trend. Environmental
Engineering staff currently occupy a substantial percentage of all these
positions - Permit Writers (50%), Water Quality Modeler (33%), Pre-treatment
Coordinator (100%), Compliance Monitoring Specialist (36%), Compliance
Engineer (70%), and Ambient Monitoring Specialist (11%).
The staff survey indicates that general biologists are well distributed
across the current and future position roster. In addition, managers
projected a future need for more specialized biologists (particularly, Aquatic
Biologists) to fill the positions of Standards Coordinator and Ambient
Monitoring Specialist. This seems to reflect the greater emphasis in the next
three years on using more sophisticated biological toxicity testing (e.g.
bioassays) in the permitting and standard setting process.
In terms of the Standards Coordinator position, Region V managers
specified that the "best fit" (in terms of occupational series) would be
either an aquatic biologist or an environmental scientist. Neither of those
occupations are represented among the three standards coordinators who
responded to the survey, with two being environmental protection specialists
and one a general biologist. While that is a small number, it does point out
an area of potential concern vis-a-vis the match between current staff
members' skills/training and changing position requirements.
Another position where an "ideal" occupational series gap might exist is
that of Pre-treatment Coordinator. However, since there was only one respon-
dent, the availability of staff members from an appropriate occupational
series for this position should be further evaluated by the Region before it
is defined as a "gap".
-------
II-8
Somewhat surprisingly, managers selected only two "best fit" combinations
for the Para-Technical Compliance Specialist position — those of environment-
al protection specialist and physical scientist — even though members of the
first occupational series are much more broadly distributed across positions
at present. In addition, there are no "best fit" combinations of occupational
series specified by Region V managers for the position of State Grants
Coordinator.
In the Ambient Monitoring Specialist position, the data shows that twice
as many occupational series are represented in the survey sample as were
identified as "best fits" by Region V managers. This finding may indicate
that given a lack of sufficient resources in the selected occupational series
(aquatic biologist, environmental engineer, and environmental scientist), the
region is now forced to assign staff members to these positions who may not
have the most ideal backgrounds. For example, fully 33% of the current
Ambient Monitoring Specialists who responded to this survey are chemists, yet
this was not selected as an ideal occupational series for this position by the
majority of Region V managers.
C. Tasks/Activities in Rank Order (by Division)
As the Region's post-BAT toxics control programs become fully implemented,
changes in the nature of the priorities attached to each task/activity are to
be expected. Exhibit 5 presents a ranking of the current Region V tasks/
activities in the order of amount of time current staff spends conducting
each.
The WD and ESD staff members who responded to the survey focus their
attention on different, but complementary tasks/activities, reflecting the
mutual dependency of each Division in meeting the goals of Region V's water
toxics control strategies. The WD respondents ranked "Identifying toxic
problems" first as the task/activity with which they are most involved,
followed by "Reviewing compliance evaluation inspections" and "Compliance
monitoring" activities. ESD respondents ranked "Review bioaccumulation
studies" first, followed by "Review of stream data" and "Conducting sediment
analyses".
-------
II-9
Exhibit 5
Rank Ordered Key Tasks/Activities
by Amount of Time Spent on Each
Key Tasks/Activities of Water Division
1. Identify Toxics Problems
2. Review/Conduct Compliance Evaluation Inspections
3. Review/Conduct Compliance Monitoring
4. Conduct Stream Surveys
5. Conduct Sediment Analysis
6. Negotiate Monitoring Plans
7. None of the Above
8. Work with States to Update Management Plans
9. Review State WQ Standards
10. Conduct Toxicity Tests
Key Tasks/Activities of Environmental Services Division
1. Review Bioaccumulation Studies
2. Conduct Stream Surveys
3. Conduct Sediment Analysis
4. Conduct Toxicity Tests
5. Identify Toxics Problems
6. Review State WQ Standards
7. Review/Conduct Compliance Evaluation Inspections
8. Negotiate Monitoring Plans
9. Calculate WLA
10. Review/Conduct Compliance Monitoring
-------
11-10
D. Post-BAT Tasks/Activities, by Positions/Occupational Series
Appendices A-6 and A-7 present the current Region V position/occupational
series and task/activity combinations. These appendices include only those
tasks/activities which respondents identified as having spent the most time
working on. For example, Permit Writers, as expected, comprise the majority
of staff resources addressing toxics problems. Compliance Engineers and
Compliance Monitoring Specialists spend the majority of their time evaluating
compliance monitoring inspections, and confronting compliance monitoring
issues. Bioaccumulation and sediment studies are primarily the responsibility
of Ambient Monitoring Specialists. Interestingly, Section Chiefs and Branch
Chiefs were identified as spending substantial amounts of time in these two
areas, reflecting both the high level attention and prioritization that these
relatively new activities are attracting from Region V management.
E. Future Critical Tasks By Position
The managers in the Phase II study were asked to identify those
tasks/activities that are critical to post-BAT toxics positions over the next
three years. Exhibit 6 presents the managers' selections of critical
tasks/activities by position. An "X" in the managers' column represents an
acknowledgement from 50% of the managers surveyed that certain tasks are
critical to each position. The actual percentage of staff respondents who
indicated they currently spend substantial time on a particular task/activity
is presented in the column labelled "STAFF".
The following observations can be made, based on a review of this data:
t Four positions are forecast as being likely to experience a
significant amount of growth in their areas of activity over
the course of the next three years:
— Standards Coordinators are predicted to have eight
activities added to the two they are now primarily
involved with. These new responsibilities will
include such things as conducting bioaccumulation
studies, and fate and transport modeling;
-------
11-11
LL
CO
LU
m
X
o
cn
_j
o
cn
O
D.
LL,
O
Z
o
LU
cn
cn
cc
LU
o
o
LU
CC
jemo
JOJBUIpJOOO
JUBJQ 8JE1S
]SI|EIOSdS
90UBi|dui03
IBOjuqos.L-ejBd
jsi|Bioeds
Ait|Bno JejB/v\
jsi|Bioeds
BUIJOJIUO^
juaiqo/v
jeeuiBug
eouBi|doioQ
IsiiBpeds
BUIJOJIUOYY
eouBi|dujO3
J8|8pOW
/fy|Bno JSJBAA
J9JUM DUJJej
JOJBUIpJOOQ
spjepuEis
jojeujpjooo
JU8UJlB8.IJ.-eJd
ja.iLio uorioes
jeiMO gouBjg
JOP8JIQ
UOISJAIQ AjndaQ
jopeajQ UOISJAIQ
W
2
03
2
W
5
c/)
2
w
s
w
2
00
2
C/3
2
CO
s
CO
5
CO
2
CO
2
CO
2
CO
^
CO
2
\OCCUPATIONAl
CRITICAL\
TASK/ACTIVITYNys^
Oi
CD
CO
X
O)
X
o
CNJ
X
X
X
o
CO
X
CM
CO
X
X
o
CM
m
CM
1 Identify Toxic
| Problems
O>
X
CO
X
X
X
X
1 Conduct Stream
Survey
X
X
X
1^.
CO
X
r-v
1 Review Stale
WQ Standards
CM
CO
X
r^-
1 Establish Permit
Limits
X
X
X
X
co
X
X
[Develop Water Quality-
Based Standards
X
o
0
1 Develop/Coordinate Pre-
Treatment Programs
•<*
X
h-
CM
X
CO
X
X
cn
X
CO
CO
X
X
r^
Conduct Toxicity
Testing
cn
X
CO
X
X
X
X
X
Conduct Sediment
Analysis
X
X
X
X
X
r-
Ifi
CM
Review Bioaccum
Studies
X
X
CO
CO
X
Calculate
WLATMDL
CO
CO
X
X
Develop Model
Mixing Zone Policy
X
X
X
Review Fate &
Transport Studies
X
X
1 Review Permit
Appeals
•<3-
CO
CO
X
in
CM
X
CD
CO
X
Compliance Monitoring
Activities
•*
X
*fr
•*»•
X
CO
CO
X
X
r^
[Conduct Compliance
Evaluation Inspections
CO
CO
CO
X
X
o>
X
X
r^
Assist in Update Stale
Water Qualily Plans
X
X
f-.
in
CM
Negotiate Monitoring
Plans
X
X
X
[Prepare Cross
Studies
POTW Sludge
Analysis
•
CM
X
o>
f-~
1 CWA
Requirements
CO
UD
CO
O>
CO
CO
Tf
S
6
rt
-
CO
CO
O)
(O
in
CM
^*-
in
CM
9
si
a £
0 *
I
g*
w (S
s%
n n
SO)
£
X
-------
11-12
— Permit Writers are likely to see an expansion of their
current role (which is primarily one of identifying
toxic problems, establishing permit standards, and
developing water quality limits) to include such new
activities as conducting bioaccumulation and sediment
studies, and fate and transport modeling;
— Water Quality Modelers could see a similar expansion
of their duties in the areas of bioaccumulation and
sediment studies, and fate and transport modeling;
and, finally
— Ambient Monitoring Specialists, Water Quality
Specialists/Biologists and Compliance Engineers may
have their areas of responsibility expanded to include
the review and development of water quality limits,
and the conduct of sediment studies and toxicity
tests.
• Current staff members are reasonably well placed to meet the
future demands of positions such as Compliance Monitoring
Specialist, Water Quality Specialist/Biologist, and Para-
Technical Compliance Specialist. As we will see in the next
chapter, while the match between projected future areas of
activity and current tasks is strong for both Water Quality
Specialist/Biologist and Para-Technical Compliance Specialists,
their self-assessment of their knowledge and ability levels in
those areas which managers predicted would be critical to
meeting these new responsibilities were the lowest of all
respondents.
-------
III-l
III. HUMAN RESOURCE STRATEGIES
A. Overview
A key objective of this project is to identify the gaps in staff capabil-
ities by assessing the current level of Region V staff members' knowledges and
abilities, and comparing these to the knowledges and abilities which were
identified by Region V managers in Phase II as necessary for post-BAT toxics
management processes. Full implementation of the Region V post-BAT toxics
control program over the next three years will lead to changes in management
priorities and the tasks currently associated with specific positions. This
evolution in the nature of a given position's tasks, and the concommitant
evolution of programmatic priorities, may exacerbate the gaps between the
capabilities of current staff members and future program needs. In
discussions with Region V program managers during the Phase II interview
study, the project team gathered information to:
• Identify those positions deemed to be of great importance to
water program toxics control activities over the next three
years;
• Identify these positions' critical tasks/activities; and
t Determine the specific combinations of knowledges and abilities
required to carry out each position's critical tasks/
activities.
The Phase III survey asked interviewees to self-assess their level of
expertise in a set of knowledges and abilities. The results of this
self-assessment were then matched with the knowledges and abilities identified
by the managers in Phase II for specific tasks/activities to determine the
potential gaps in current staff members' knowledges and abilities vis-a-vis
evolving program needs.
-------
III-3
Table III-l
Rank Ordering of Knowledges and Abilities
Rank
1
2
3
4
5
6
7
8
9
Rank
1
2
3
4
5
6
7
8
9
Based on
Total Weighted
381
304
295
291
286
285
260
221
147
Total Weighted
407
375
368
311
282
274
272
271
257
Staff Members' Self-Assessment
Score Knowledge
Biol. & Phys./Chem. Prin.
Env. Eng. re. Trmt. Processes
Clean Water Act/EPA Policies re. Toxics
Org. Chemistry, Toxicology ... other related
Sciences
EPA/State Regulations
Industrial/POTW Processes
Aquatic and Human Health Effects
Legal Issues re. Toxics
Toxic Modeling
Score Ability
Oral/Written Communication Skills
Manage Projects
Maintain Liaison with States
Evaluate Contractors' Work
Resolve Regulatory Violations
Conduct Computer Data Analysis
Conduct Field Inspections
Interpret Agency Policy
Serve as Technical Expert/Witness
-------
III-4
• Abilities: The abilities to communicate orally and in writing,
with both scientific and non-scientific groups, and to manage
projects were clearly identified as the most frequently used by
Region V staff for all tasks and activities. And, here again,
the majority of the staff members who selected these as fre-
quently used abilities also ranked their competency levels as
high or medium in these abilities. Only one staff member's
self-assessment was at the low/non-existent proficiency level.
Project management is another ability which was identified as
frequently used, and which also had a high percentage of staff
members who ranked themselves as very proficient.
Table III-l and Appendices A-8 and 9 present the data from which a compar-
ison has been made between the staff members' knowledge/ability self ratings
with the managers' rankings of the key knowledges and abilities required for
each task. The most important finding to note from this comparison is the
close correlation between the staff members' rankings of their knowledges and
abilities levels and managers' rankings of critical knowledges and abilities
across tasks/activities:
t The knowledge most frequently cited by managers, across all
tasks/activities, is the knowledge of chemical, biological, or
physical science principles. The next two most frequently
cited knowledges are: the knowledge of theoretical and
practical concepts, principles, and practices in the area of
wastewater and industrial processes, and the knowledge of
current concepts and practices in chemistry, toxicology and
related environmental disciplines. The Region V staff members'
self-assessment of their competencies (and use of these
knowledges)-coincided extremely well with the managers'. Staff
members cited their knowledge of chemical, biological, or
physical science principles as being the one they used most
frequently, and the most highly developed, followed by their
knowledge of current concepts and practices in chemistry,
toxicology and related environmental disciplines.
-------
nr-5
• The staff differed slightly from the managers by ranking their
knowledge of the Clean Water Act third in importance, while
managers rated it second, perhaps reflecting Region V
management's commitment to pursuing a more active role for
toxicity testing in post-BAT management programs, since the
managers were asked to rank knowledges and abilities vis-a-vis
their importance to the water toxics program in the future.
• The managers ranked the knowledge of current concepts in
chemistry and bio-chemistry third, and the knowledge of EPA and
State regulations pertaining to the evaluation of wastewater/
industrial treatment facilities' design and operation fourth in
criticality, while the staff ranked these two knowledges fourth
and fifth, respectively.
f The ability to communicate orally and in writing, with both
scientific and non-scientific groups, and the ability to manage
projects and programs were ranked first and second by both
managers and staff as the abilities most needed for performing
future post-BAT toxics control tasks. The ability to conduct
complex field inspections at industrial facilities was ranked
third by the managers, while staff rated the ability to main-
tain liaison with State agencies as third, possibly reflecting
the frequency of staff member's day-to-day contact with State
EPA offices concerning water toxics issues and development.
2. Staff Knowledge and Ability Levels As They Relate to Critical Tasks
Currently Performed
Another aspect of the analysis of Region V staff members' knowledges and
abilities can be derived by arraying the aggregate staff members' self-
assessments on the ten knowledges and ten abilities vis-a-vis their predicted
importances in performing key water toxic program tasks/activities. For
purposes of this comparison, we have defined "key tasks" to be those which
Region V staff members have indicated that they spend the most time on. As
seen on the Exhibit below, they are, for each Division, as follows:
-------
III-6
Water Division
(1) Identify Toxics Problems
(2) Review/Conduct Compliance Evaluation Inspections
(3) Review/Conduct Compliance Monitoring
Environmental Services Division
(1) Review Bioaccumulation Studies
(2) Conduct Stream Surveys
(3) Conduct Sediment Analysis
For the task of identifying toxics problems — which was ranked first for
Water Division staff — the self-assessments of those respondents who reported
spending time on that task indicate high levels of competence in several key
knowledges (see Appendices 8 and 9). For example, for the knowledge of
chemical, physical and/or biological principles, thirteen of fifteen respon-
dents indicated they have significant levels of expertise, including eight who
rated themselves as experts. There was a similarly strong self-assessment in
the area of knowledge of organic chemistry/biochemistry.
However, there were several knowledges which Region V managers have
identified as being important for identifying toxics problems in the future
where staff members rated their current level of expertise as minimal to
non-existent. These included such things as toxic water modeling, where half
the respondents (e.g., eight of sixteen) assessed their skill in this area as
non-existent. A similarly low self-assessment was found for knowledge of
legal aspects related to this task.
For the second most common task among Water Division respondents — that
of Reviewing/Conducting Compliance Evaluation Inspections -- the knowledges
where staff members indicated striking skill gaps were those of:
• Toxic Aquatic and Human Health Effects
-------
III-7
• Toxics Water Modeling; and
• Legal Issues.
Conversely, these respondents indicated significant expertise in the
following knowledges:
• Environmental Engineering re. Treatment Processes;
• Clean Water Act/EPA Policies re. Toxics;
• Wastewater Treatment processes; and
• Chemical, physical and biological principles.
Of the above groupings, knowledge of legal issues was selected by Region V
management as being especially critical to this task in the future, along with
the knowledge of chemical, physical and biological principles.
For the task which ESD staff members reported spending the most time on --
reviewing bicaccumulation studies -- two of the three self-assessments
indicated a weakness in the knowledges of toxics modeling and legal aspects,
while all respondents described themselves as having considerable knowledge of
chemical, physical and biological principles, the Clean Water Act, and organic
chemistry and biochemistry. The first and last of these knowledges were
selected by Region V managers as being critical to performing this task in the
future.
For the two respondents from ESD who conduct stream surveys — the second
ranked ESD task — one reports a substantial level of expertise in physical,
chemical and biological principals; and both had adequate levels of knowledge
regarding the Clean Water Act. Both of these knowledges were selected by
Region V managers as important to this task's future activities.
-------
III-8
On the task which ESD respondents ranked third, in terms of the amount of
time which they spend on it -- conducting sediment analysis -- weaknesses were
identified in the following knowledges:
• Environmental Engineering vs. Treatment Processes;
t Clean Water Act/EPA Policies re. Toxics;
• Wastewater Treatment Processes;
• Toxics Modeling; and
• Legal Issues re. Toxics.
In fact, of the two respondents who indicated they performed this task,
only one ranked himself as being expert in any relevant knowledge, and that
was of chemical/physical principles. On the knowledge of human health
effects, which was selected by Region V managers as being critical to
performing this task, the two respondents rated themselves as having minimal
knowledge.
In the category of key abilities as they relate to the tasks which Region
V staff members reported that they spend the most time on, an ability which
cut across the top three tasks, and for which mimimal ability was identified
is that of working with computers. On the other hand, significant strengths
were reported in the following abilities which were also identified as being
critical to the top-ranked tasks listed on page III-6:
• Managing projects;
• Written/Oral communications;
• Conducting Treatment Facility Inspections; and
• Maintaining Liaison with State Agencies.
-------
III-9
3. Comparison of Staff Members' Self-Ratings in Knowledges and Abilities
which are Critical to Specific Positions
A third aspect of the identification of potential "skills" gaps process
involves specifying gaps in skills which are considered critical to accom-
plishing the key tasks of a position. To do this, the project team evaluated
the Region V managers' selections of critical tasks for all positions for
which such data was available. Having identified the task/activity which the
managers ranked as the most critical for these positions, the project team
reviewed the results of the Region V managers' interviews in which they also
specified the critical knowledges and abilities for that task. By combining
the results- of these two analyses, the project team produced a list of
critical knowledges and abilities for the top ranked task for each position.
The project team then reviewed and "scored" the self-assessments of the Region
V staff member for the critical knowledges/abilities for each position's
critical task.
The "scoring process" involved categorizing the aggregate "level" of staff
member expertise in a knowledge or ability by reviewing the distribution of
self-assessments of staff members for each knowledge and ability, and classi-
fying each distribution as follows:
If 60% or more of respondents rate themselves as having
"advanced" or "intermediate" levels of expertise, the know-
ledge and ability was rated as being "HIGH" for the entire
sample;
If 60% or more of respondents rate themselves as having "low"
or "non-existent" levels of expertise is given knowledge or
ability, the level of expertise of the entire sample was
rated as being "LOW"; and
If there was an even split between the self-assessment of
expertise for a given knowledge or ability, the level of
expertise for the entire sample was described as being
"MIXED1.
-------
111-10
The results of this overall analysis are summarized, first for knowledges
and then for abilities, in Exhibits 7 and 8. Exhibit 9 presents a combined
display of both the knowledge and ability aggregate ratings for each position
for which "critical" knowledges and abilities were specified by Region V
management, while Exhibits 7 and 8 break them down separately for all
positions.
An examination of the Exhibit 7 and 8 data reveals the following,
vis-a-vis the expertise levels of position incumbents for the ten abilities
and ten knowledges:
• There is no knowledge or ability for which significant levels
of expertise do not exist somewhere among the respondent pool;
• The Pre-Treatment Coordinator and Standards Coordinator posi-
tions have incumbents whose expertise levels are almost
uniformly "HIGH" for all knowledges and abilities;
t The respondents who occupy the Water Quality Modeler position
have expertise levels which have been categorized as a "MIXED"
for virtually all knowledges and abilities; and
• The respondents who occupy the Para-Technical Compliance
Specialist position self-assessed as having low or non-existent
levels of expertise across all knowledges and abilities.
Exhibit 9 arrays the data, for the nine positions, using those knowledges
and abilities which Region V managers predicted would be critical to future
performance in a given position. A review of this data reveals that:
• For four of the nine positions, aggregate rankings for both
knowledges and abilities were "HIGH" for 75% or more of the
critical knowledges/abilities. These four positions are
Pre-Treatment Coordinator, Standards Coordinator, Compliance
Monitoring Specialist, and Compliance Engineer;
-------
III-ll
CO
O
CL
03
CO
LU
H
-J
r^ CD
t*
ggz!
x<
XLL
LUQ
CO
<
DC
g
X
5
0
<
2
CO
*
CD
m
5
CO
C\J
^^y
^J[
p- I
Ij /
00 /
/o
/ t
/ o
/ Q.
Division Director
Deputy
Diviston Director
o
CO
Section Chief
X
X
X
X
X
X
X
X
X
Pre-Treatment
Coordinator
i .
1
X
X
X
X
1
1
1
1
1
1
—1
Standards
Coordinator
X
-
_J
X
-
X
X
_J
1
1
1
-J
i
0}
0-
t
i
i
i
i
i
t
i
i
i
i
i
i
i
i
i
•
i
i
i
i
i
i
Water Quality
Modeler
X
-
•
X
_J
X
X
1
1
1
1
1
1
X
'ompliance Moni
toring Specialist
-------
111-12
O
H:
CO
O
Q_
m
CO
UJ
co e
5
O
T—
O5
00
£
CD
S
2
CO
CVJ
5
UJ /
O /
LU /
l/z
7 1
/ °-
Division Director
Deputy
Division Director
"5
IE
O
o
00
en
3
6
1
CO
X
X
X
X
X
X
X
X
X
IPre-Treatment
Coordinator
i
i
I
X
X
X
X
1
1
1
1
1
1
1
1
1 Standards
Coordinator
X
-
-
-
-
X
X
_J
_l
1
1
1
Permit Writer
i
i
i
i
i
<
•
i
•
•
i
•
i
i
-
i
i
•
i
i
•
i
•
1 Water Quality
Modeler
X
-
-
_J
-
_l
X
X
1
1
1
1
1
1 Compliance Moni-
toring Specialist
-
-
-
-
-
X
X
i
t
Compliance
Engineer
X
-
-
i
i
-
X
_J
_)
1
1
1
Ambient Moni-
toring Specialist
X
_J
_J
-
:
i
X
_j
_j
_j
Water Quality
Specialist/Biologist
-
-
-
-
-
•
i
-
-
li
o .51
2 8
JJ
X
-
_j
_i
-
_j
X
-
_J
—1
<5
0
I
X
_J
-
-
_J
1
1
1
X
1
1
1
_J
-
State Grants
Coordinator
XLJL
LUO
CO
O
P
DC
|
X
-------
111-13
o
<
o
b
CO
O
Q.
CD
CO
LLJ
H
00
<
03
X.
f-.
<
XLL
LUO
CO
O
I
DC
g
IE
o
0)
.2
.52
a
o
o
0.2
'5
5
.2
a
u
§
m
03
O
o
CO
(Q
.
OJ -
ra o
CO
O
en *—
3 »
O «
CO'
0~
2 co
05 1
g,Sj
•— 52
ol
^53
CO CO
ou
tn
0)
CO
If
<2
II
o ra
O'5
s =
C8.S5
-------
111-14
• For two positions, there are aggregate rankings of "HIGH" for
all critical knowledges and abilities. These two positions are
those of Pre-Treatment Coordinator (for which there was one
respondent), and Standards Coordinator (which had two respon-
dents);
t Three of the nine positions had a notable preponderance of
"LOW" ratings, including that of Para-Technical Compliance
Specialist, which had aggregate ratings of "LOW" for each
critical knowledge and ability. The other two positions are
those of Water Quality Specialist/Biologist, and Permit Writer;
and, finally,
• For the position of Water Quality Modeler, the aggregate staff
ratings for all but one critical knowledge were rated as
"MIXED", indicating an even split between "HIGH/LOW" ratings
for each knowledge or ability.
If the data on Exhibit 9 is examined by scanning down each column, it
shows:
t A marked number of "MIXED" and "LOW" ratings for knowledge of
Wastewater Treatment Process, Legal Issues, and Toxics Water
Modeling;
• A significant number of "HIGH" ratings for knowledges of
Chemical, Biological and Physical Principles; and
• A substantial number of "HIGH" ratings for the abilities to
Manage/Conduct Projects, Maintain Liaisons with State Agencies,
and in Written and Oral Communication.
In addition to these general observations, Region V management may also
wish to address potential skill "gaps" from a position-specific (rather than
staff-wide) perspective. The project team has aggregated the various findings
so that they can be evaluated from that perspective, and the results of this
analysis are summarized in Exhibit 10. The highlights of the findings for
each position are discussed below.
-------
111-15
o
H
03
I
X
LU
I/I
LU
01
01
UJ
z
£
UJ
2
a
z
t/i
r
o
z
UJ
^_
I/I
u.
u.
^
01
^
Z
UJ
X.
a.
a.
01
UJ
u
o
a
a.
j
o
a:
H
z
o
u
i/i
u
x
o
h-
>
Z
a
M
(J
UJ
f£
U.
O
j.
X
i
3
01
I/I
UJ
I/I
UJ
z
^
u
^
z
UJ
a
a.
a
^
4/5
X
H
Z
UJ
10 — *" Ol
i/i oi Q. c c I/I
C • UJ
01 ~ Z
c *
1 0 <
•f- LU
- 41 2
^ 18
w L. H
01 Z
•o a LU
0) 0 CE
x <
— T3 fl.
EC 0.
m
IB C
ai
T3 —
01 in
4- 01
IB 'O
L
in >
0) 41
< u "-
01 —
•0 i -
c u •
18 O IB C
3t H- O
in 41 —
1 41
* • c
m CM o)
>— • ^ 41
(8 X 4J
U "D IB
•o c
41 01 IB 1-
•r- 41 01
1- IB - £
u L. in 41
i in i_
41 Z 01 3
in o u 14- 01
o-o r
E L. 01 1-
M a e , <
C — IB
0 T3 01 E
- -DC
41 IB — in
U 18
in 01 oi
o c 01 i-
Q. — C IB
• 41
UJ
^J
*«
H
Z
O
t-
jj
o
CL
4J
C
11
£
4-»
B VI I/I
01 41 C
t. u o
4- 41
«- u in
01 a> m
01 d 01
t. £ we
41 C 41
•*- •!-
O) 18 I
C 4> > ^
••- £ 41 41
L ••- L
01 C — 01
01 .U — Q
C E U X
3 re 01
01 £ »-
c —
01 "D 41 18
c e u
(8 Ol 01 •*-
C E C
— U — 4i £
(B •• IB U
41 41 01 01 01
C IB U L 41
oi in 3 o 41
E Ol £7 E in
C in 18 41 (8
o in w u
u 01 u u 3 oi
•»- u •*• "• "O >
> 0 X X C L
C L O O 0 01
01 0.41 41 o in
r~- r*. ao •— ro
* * * < <
.—
IB
U
~-
in
>«
L.
a
•D
c
IB C
0
•^
41
— (8
ig u
u —
"~ C
Ol 3
0 E
— e
o mo
— 41 U
a u
01 —
—> IB
in o i.
• oi u o
— •— d ^.
IB a c
U •-- 0) ffl
— U Ol 41 10
E C IB 41 Ol
0) ••- C — C
£ L. IB L —
o a 6 z t)
c
-a —
— 01 CO)
— L IB O
£ —
•- T3 in o
in c 'O —
c IB t. a
O IB ^
a ti 4-
in 41 e in
01 C 18 —
L 01 41 —
E in IB
m a
- 0 O u
C — S 01
o 01 a
— > oi m
41 01 £
- -a ~ a
m- 3
O 41
a is 01
in £ £
in "o 41 41
•*- i-
£10 ifl O
41 ^ — 41
C -
IB — -a
01 *i a 01
> i/i i/i t-
01 u
— 0)
— O 01 14-
01 X • £ ifl
£1 U 41 C
41 (8
Ol 01 1-
Ifl C 14-41
L. — - O
01 41 in oi
01 u 41 a
IB 01 — >
c *. S ex
IB **- ••- (B IB
S IB - Z E
• •
01
—
a
IB
L
••-
m
01
•Q
>,
~
,c
Ol
f
£.
01
d
>^
(B
E
in
41
u
Oi
>4.
i*.
0)
£
•_
IB
01
£
U
•*•
x
O
41
C
01
c
c
18
^
1-
•
-------
111-16
I/I
UJ
y}
V)
HI
>-< Z
•a *
9) <
3 UJ
C X
** 1—
c z
O UJ
u ee.
** a.
ui a
UJ <
V)
1/1
UJ
z
5£
^
UJ
X
a
z
<
1/1
r
0
z
UJ
tr
1/1
u.
u.
4{
h-
l/l
o
— t-
z (n
1- UJ I
— SC H
ffl < O
HO, Z
r a. uj
x < a:
UJ- • H
1/1 VI
10
UJ I-
u z
O UJ
K K
a <
_i a.
o <
a
z
o
u
VI
u
X
o
o
Mrf
13
01
X
u.
O
^
at uj
1 £
3 t-
l/l
Z
O
H-
2
in
C
o
•1-
4J
u
u
a
in
c
X
4_»
.,.
«.
.1-
o
ra
14-
4^
C
u
E
oi ra
c o
— •*•*
9)
•a oi
o c
£ •*-
4-<
. — O
£ 91 -
a c *•
a
•o u
— c —
n a c
U 3
01 (0 E
O U U) O
— •— 4- U
o E u
O C. '~t (0
u o t-
1. O
10 0 C
U f O O
i- c oi *< in
HI IP 01 C ~ C
C — I- 10 >. —
u a o E x T3
c
V CO «T («• —
* * < < U.
O)
II
C
^«'
t-
O
~ 01
— C
l_
C 0
O 4-
Ul —
•»- c
in in o
ra -^ E
Hi —
L 't-
10 HI O
>
— ••- tfl
•ME
U L 1/1
JC HI Q) £
in 14- 4- K
**- (3
>• 0 C Z
HI — UJ
jc c a
••- 0 K
c n u M
— *• 3
c ~ t-
a» - 3 z
C 10 •»- UJ
0 E K
I. C <
*- o - a
I/I 4^ Q.
** ^
C C
o > ra
•^ 4^ 4^
*• — L.
•*• •— O
U) -^ Q.
o ja e
a. < —
* *
UJ
* J
H
H
Z
O
Hll
^»
j"J
o
a.
HI
c
o
•z
—
ra
u
•*-
in
>s
c
a
•o
^
ra
^
(0
u
.^
01
0
o
a
in
. .—
— ra
n a.
u —
•<- u in
S C 01
HI — C
r i. —
u a T3
c
^ -f-
X U.
•~
II
c
^r
a
UJ
j
al
Q
O
S
£
-1
^
3
a
a
UJ
t-
^;
3
B o
HI 4-"
in
in «
HI X
l/l HI
in 4^
ra c
o
HI U
u
HI C
V)
cm uj
0 - M
< i/i
^ UJ
•o z
in c *
o ra <
n UJ
a
o *• a
t- o a
^
« ^
ra —
u
HI HI
^ v £ 1.
T ~ 3
* L ~
s^ (J '4-3
0 *-
C Ul
O 10 HI C
•*- u •*•
*• in c
— U !0 E
in HI ~ L.
o 01 i- o
a ra o *-
c a t.
m 10 EH)
E - a
r
*• > HI —
a £ -
0 13 X
<4- HI m
••- in c
£ 14- HI O
oi ••- in ••-
"- 4J I/I 4-1
r c ra — 10
HI in r
13 T3 O O • t-
IB *. a is
•" Z
ra 10 jc z
— E m UJ
x in ra K
0 - *• <
c x • c a.
Jt : 0 X Q.
1-13—1) <
HI HI HI OI C
C £ x 9)
O « — a -
O E —
— 9i a
c *r w £ £
O — 10 I- »•
. . .
UJ
J
^
H
z
o
M
K
*"
2
HI
c
o
z
— I/I £
a HI ~
u u —
•- C 10
in HI 91
>. — £
£ U
a in
c
^ ra
t) HI E
C ~ 3 in
ra ra £ HI c
- — o
HI U ••-
L C X-w
— ~O HI O (0
n T; c 0) — u
u c 10 ra — —
— ra o c
0) 41 a 3
— 10 U 10 >> E
o u •- in *- u o
— — 4J V 1/1 C U
£ E W U 9)
HI 3 9) £ 01 —
in o a o •- u
• HI L J 4- O
• a 91 ^
io a u in c L c
U**~~~in*'9IOQ.9l
"-UCUUOiUl^-4-*
£CtO**~H)<0>*-91+''
91"- O1X«4- C (04-»~-
£^l-Ol*-(Q'^Ct-
uao4^9iE — *^x
^ (O Is* ^ l/l CO h*
X * * < < < <
--S
n
II
c
HI •
V- T3
1)
O >
L
- a
c =
ra *~
x
HI
>.£<
E 13
3
C O
O £
•- in
oi
HI in
cr -
<
HI 13
£ C
K ra
-------
111-17
0
^»
|M
»H
ffi
N-l
i
UJ
^^
•a
0)
c
^
c
o
u
I/)
UJ
I/I
10
UJ
z
51;
^
UJ
S
a
z
^
i/)
z
t-
u
z
UJ
a
i-
1/1
u.
u.
4
1-
1/1
H-
Z
UJ
K
a
a.
^
(/)
UJ
u
o
a:
a.
j
0
a
z
0
u
V}
u
IM
X
0
z
o
3
UJ
a
u.
0
^
a
^
z
z
10
1/1
UJ
i/)
UJ
z
^
UJ
2
t-
Z
UJ
a
a
a
^
(^
^
^
O
z
UJ
ac
i/i
^»
z
UJ
Z
^
Q.
&
^
UJ
_ J
H
H-
Z
O
"
M
V)
O
a.
. u
£ 0)
a a
in
c
•a ••-
c
IB >.
44
^>
^
M *-
IB U
U 18
a
o 44
— c
a o
- E
a *•
IB
0)
in L
. O 44
— —
IB a*-
u — u
— O 3
E C -0
11 — C
£ L 0
u a u
^ *~
sc <
4-s
v^
r*
II
c
-~*
in
11
u
c
11
01
IB
01
4rf
(8
in 4w
V I/)
u
01 £
O'-
L X
a
c
01 O
ai in
IB —
C IB
18 f
E -
T in
< <
c
o
• r-
4rf
IB
u
c
E
E
o
u
_
18
L
o
^
c
01
+J
44
•r-
L
X
^
<
^
Ol
^
•a
c
<8
in
s- 1
Q
4J
+J
a
0)
(J
X
01
in
<
•o
c
(8
in
^
n
1)
L
.^
3
CT
11
L
—
^>
(8
c
0
11
4-1
18
3
(T
01
•o
10
L
o
r
0)
£
•o
01
Jt
c
m
L,
c
o
^~
in 4^
Ol —
c »i
•*• o
•a a.
c
U- •
4J 4J
c c
1) (8
E x
a >-
01 (8
L £
11 C
L 0
01
• 01
• a:
01
• 1)
(U £
in —
L «
0) .-
O) in
18 X
c —
ra IB
E C
18
>,
J3 >
a
"D >
01 L
— 3
4. in
•r-
" E
C (8
Qi 01
•0 L
"- 4^
in
in
(8 D •
c in
> 18 18
4* fl)
••- • L
— W 18
•r- .^«
£> in »
•- > in
« — 0)
C 18 £
O C 4J
a. IB
in c
0) ** •*-
L C
oi in
»- £ -
o -^ —
u -
in 11 jc
(8 in in
01
L - 01
IB 4J C
c —
TJ O >
01 E 0
TJ a L,
c o a.
IB - E
a. a —
x >
01 (V L
t) 01
41 D
£ ••-
** E in
(B C
C L o
41 Ol U
> o
— L O
o a*'
*
10
UJ
I/)
(/)
UJ
z
2C
4
LU
3t
^M
z
UJ
a
a
a
^
l>1
I
^l»
o
z
a:
^»
I/I
H-
z
UJ
a
^
a
a
^
UJ
J
V-
H
z
0
t-
1^
(/)
0
a
1
1
1
4-1 1
C i8
11 L
E u in
w a u
fl O — Jl
11 x Q
L -o o o
IB 4J
u
C U 01
ii ai L a
L in
in in c
11 11 .r-
O) T3 —
c u >.
••- >. -^ 4J
L 4-« — -.-
ii — o in —
ii — a. u —
C — — u
U < x 18
01 TO a. o y-
C 4- UJ 4J
11 -X 4J
< • c
S U 01
01 U L E
— L 4J
IB "«- in IB
4J O U 01
C C 3 L
m in o 0) in 4^
Em— 01 m
c in •" u — *•
O Ul (8 D U
1. 1) _ 3
••- U 3 C X 18 T3
> O 01 Q O 01 C
C L 01 — C 11 O
01 a. L 44 i — u
— N in o) —
•^ >f ~< *^ ef
in
Ol
^
.^
01 T3
c c
o ••-
Z u.
1
-1
*
u
UJ
a.
1/1
u
u
z
—
a
£
o
(J
_J
^
o
z —
X f"5
LJ —
UJ II
h- C
1 w
^
a; t-
a —
11
a m
01
> in
(8 . • (0
— in u
C (B -
O 01 -w
L •-
18 L
L U
11 X
> 11 44
01 i in
X O
o 13 E
£ 11
••- 01
in — * •*- **
IB - 44
0) < c x
L 01 4.
IB • U •<-
in -• *•
— * c
— 1-01
i N £ •-
in it 44
o >
>* • •—
01 - —
^ 01 C 3
— 01 01
(B ^- • L
L oi m 18
01 01 44 01 U
> O 18 —
01 c 3 a o
in IB ff"- v
E 0) o
c L 13 c m
— O 18 — -r-
4- L
m L a ai
01 4) 01 L
in a. L — u
in IB 18 c
01 O U
CO — a
jc •*! in m 3
IB — >. in
ii o u £ in
x *" > a •-
u -^
44 44 C
C C (8
01 10 u m
L > — — E
IB 01 — E
a— — oi o)
a D i £ c
< L, 1/1 O K-
• • •
-------
111-18
O
^
Ij^
ffi
X
x
LU
~
f^
D
0
3
C
44
C
o
u
^^
10
UJ
z
^
UJ
2
a
z
*
z
z
UJ
ce
u.
a.
1-
t-
z
UJ
ce
CL
a
^
»
m in 44
13 5) •-
O L
> O O
4^ 1- Ifl C.
•r O. U 44
— — 3
•^ 44 X (9
O C 0
(9 0) 44 —
4- E 19
44 . O
• 19 01 •>-
0) 0) I- C
L;. r
44 Ifl U
Ifl (U 01
C I- 3 4-
O 01 Ifl
•^ 44 Ifl Ifl
v (9 •— 19
1C I
.— Q) — <])
3 4v (9 >
Ol Ifl O) l-
01 !9 01 01
l_ J — Ifl
(N C*7 £71 C*5
01
01
.*-
U Ifl
— a c
— •.- o
o u —
a c «
0) 19
< Ol U
a a «-
UJ C
01 3
< ra e
3 *• o
O l/> O
*• £ -
0 4V 19
11 I O
at •**
•o c c
0) O O
— Ifl 4V
X '^ 4V
0 19 "-
C — l-
i — I
in (O r*"
*«£ <
co
it
C
a
UJ
i-
a:
3
a
UJ
a.
.
<
tJ
c
19
(fl
_
19
U
^
44
•^
C
U
n
c
JC
Ol
M—
c
in
01
c
+rf
19
IT
B
Ifl
(0
01
19
C
10
44
L
o
a
E
L
<-
r
44
O
19
u
01
01
Ifl
c
r-
X
nj
01
1/1
.r-
C
O
•^
44
f
a
a
a
u)
0)
4V
(0
u
.1-
•D
C
C9
4M
19
a
%
0)
u
0)
IB
01
C
01
3
*-<
01 x
— u
*: o
•-V 44
(9
in —
a 3
01 Ol
U 3)
(0 U
— 01
(9 >
U —
•r- O
.- .
U <4-
01 .-
4- C
a 01
a
CN —
C I
CN
^
01
4V t)
<9 C
3 19
a
0) •
"O I/I
(Q 91
Ifl
Ifl
•a «
01 U
44 O
19 L.
i- a
44
e c
O 01
- e
-4-* *^
M- (0
wi d)
0 U
a 44
•
-------
111-19
For the position of Compliance Engineer, the seventeen respondents who
currently occupy the position assessed their levels of expertise as high for
most of the knowledges and abilities which Region V managers identified as
being critical to performing that position's key tasks. The members of this
group rated themselves as having low levels of expertise in two key knowledges
— those of the Clean Water Act/EPA policies re Toxics, and Legal Issues re
Toxics. Given the nature of this position's duties, it is also useful to note
that the sample's self-assessment of expertise was "mixed" (i.e., half the
sample rated themselves as "high" and half the sample rated themselves as
"low") in the knowledges of environmental engineering re treatment processes,
and facility design and operation.
Region V managers predict that the duties of the Water Quality Specialist/
Biologist position will expand to include developing/reviewing water quality
standards, setting/reviewing water quality-based permit limits, and reviewing
the results of bioaccumulation studies. Of the key knowledges and abilities
Region V managers identified as critical for this position in the future,
eleven respondents who currently occupy this position rated themselves as
strong in their knowledge of chemical, biological and physical principles, but
weak in their knowledge of:
• environmental engineering re treatment processes;
• toxic aquatic and human health effects; and
• toxics modeling.
They were also low, as a group, in their ability to conduct treatment facility
inspections and to serve as technical/expert witnesses.
While there are a number of possible techniques to enhancing the expertise
of this group in the above knowledges/abilities, one relatively immediate
option available to Region V management is to have the current incumbents of
the Pre-Treatment Coordinator and Water Quality Standards positions act as
"consultants" to the Water Quality Specialists/Biologists on issues relating
to toxic aquatic and human health effects and toxics modeling, since the
incumbents of the pre-treatment coordinator and water quality standards posi-
tions assessed their levels of expertise in these two knowledges as "high".
-------
111-20
In addition, it would also be advisable for Region V management to provide
additional training to staff members in toxic health effects, particularly for
those staff members who occupy positions where gaps in that knowledge have
been identified (e.g., permit writers, compliance monitoring specialists,
compliance engineers, water quality specialists/biologists, and paratechnical
compliance specialists).
The Water Quality Modeler position, while not reporting any "LOW" ratings
for its key knowledges or abilities, did show "MIXED" ratings for fourteen of
the fifteen identified knowledges/abilities. These results are particularly
worrisome in view of Region V managers' prediction (in the Phase II survey)
that this position's duties would have eleven new tasks added to it in the
future. Since the occupants of both the Standards Coordinator and Pre-
Treatment Coordinator positions assessed themselves as "HIGH" in seven of the
eight key knowledges where the results for Water Quality Modeler incumbents
were "MIXED", Region V management should consider the feasibility of:
• Detailing Water Quality Modeler staff to the Pre-Treatment or
Standards Coordinator positions to improve the affected skills.
• Using the Pre-Treatment Coordinator or Standards Coordinators
as "advisors/consultants" to the Water Quality Modelers on
complex issues where the former have expertise; and
• Having the Pre-Treatment Coordinator and/or Standards Coordi-
nators develop some in-house training programs to enhance Water
Quality Modelers' expertise in the most critical knowledges and
abilities.
The occupants of the Ambient Monitoring Specialist position rated them-
selves as "HIGH" in all critical knowledges and abilities except the knowledge
of toxics modeling and the ability to conduct treatment facility inspections.
Since these latter two are areas which are important to the evolving role of
the ambient monitoring specialist, Region V should consider how best to
supplement their staff members' level of expertise in these areas. Since no
group of respondents rated themselves as "HIGH" in toxics modeling, this may
-------
111-21
be an area where a targeted training program, using university or contractor
resources, would be beneficial. It is also possible that Region V staff
members in other programs possess sufficient expertise in this area to assist
in developing an in-house training program in toxics modeling. Depending on
Region V management's assessment of the degree of demand for this knowledge, a
specialized recruitment effort to hire an expert in this field might also be
appropriate.
The findings for the incumbents of the Compliance Monitoring Specialist
and Pre-Treatment Coordinator positions showed substantial strength in
virtually all of the key knowledges and abilities identified for these posi-
tions. This is an important area of program strength for the Region, and
should also be utilized as a resource in buttressing areas of weakness in key
skills among the incumbents of other positions. The two areas where the
Compliance Monitoring Specialist incumbents noted some weakness were in their
knowledge of Clean Water Act/EPA policies re toxics and legal issues re
toxics. Both of these knowledges are amenable to targeted, in-house training;
and Region V management should move to address this — particularly in the
area of legal issues re toxics, since incumbents of four of the six positions
where this was identified as a key knowledge assessed themselves as "LOW" in
their level of expertise.
Finally, the findings for the positions of Para-Technical Compliance
Specialist and Permit Writer reveal numerous areas of weakness in key know-
ledges and abilities. Given the nature of their position's duties, it is
especially noteworthy that incumbents assessed their expertise as "LOW" in the
knowledges and abilities re:
• environmental engineering re. treatment processes;
• regulations re facility designs and operations;
• knowledge of the Clean Water Act/EPA policies re toxics; and
• ability to conduct treatment facility inspections.
An examination of the overall results shows that these are areas of weak-
ness across most of the positions in the Water program. Incumbents of the
permit writer position appear to be weak in the same and/or similar knowledges
-------
111-22
(e.g., wastewater treatment processes, regulations re facility design and
operation, and legal issues re toxics). In fact, the results of the survey
indicate that Region V staff members assessed themselves as either "LOW" or
"MIXED" in four key knowledges across all positions requiring those
knowledges. They are:
• environmental engineering re treatment processes;
• regulations re facility design/operation;
• toxic water modeling; and
• legal issues re toxics.
Since the level of in-house expertise is uniformly low, the most likely
strategies for closing these "gaps" in key knowledges include:
• targeted recruitment efforts to acquire staff members with
expertise in treatment process technology and facility design/
operation, and toxic water modeling; and
t focused, in-house training in the knowledge of the legal issues
re toxics.
Given that the latter knowledge is most likely to reside in Agency staff from
other programs, those resources would be the most cost-effective source of
course designers/instructors for this training program.
C. Program-wide Strategies to Address Knowledge and Ability Gaps
In the preceeding section of this chapter, the project team identified the
"gaps" between the knowledges and abilities that will be required to fully
implement the post-BAT water toxics control program over the next few years
and the current staff's self-assessment of their competency in these
knowledges and abilities. In this section, the project team will present
various human resource strategies that Region V could employ to address those
gaps.
-------
111-23
The specific topics which will be covered in this section of the document
include:
• Potential human resource management strategies which Region V
management can employ to ensure its staff has the appropriate
knowledges and abilities to conduct the key tasks of its water
toxics control program;
• Specific strategies for dealing with gaps in critical
knowledges and abilities, by position; and
• Discussion of post-BAT water program tasks where low levels of
staff member knowledges and abilities were identified.
1. Description of Possible Components of a Human Resource Management
Strategy
Region V has an experienced, dedicated staff with adequate or better
levels of expertise in most of the key knowledges and abilities for most of
its critical tasks. As it continues to implement the post-BAT toxics control
program, it is important that Region V management focuses on developing an
acceptable level of competency among its staff members in all critical
knowledges and abilities, and an appropriate amount of staffing depth for
those positions whose duties are expected to see significant growth and/or
change as a result of the shifting programmatic emphasis.
There are a number of potentially useful techniques which Region V
management should consider, including:
• Training, which is a measure that is particularly suited to
enhancing staff members' capabilities in such areas as:
-- Knowledge of EPA/state regulations;
-- Knowledge of industrial processes;
-- Knowledge of legal issues;
-- Knowledge of the Clean Water Act;
-------
111-24
~ Knowledge of human health effects; and
— Knowledge of toxics water modeling.
The methods for delivering this training can include such techniques as:
on-the-job training, classroom-based training offered by colleges, universi-
ties, private-sector contractors, or the EPA Institute; workshops and seminars
to be developed by Region V staff members; and computer-based training.
Exhibit 11 presents Region V staff's responses concerning the degree to
which they believe they have received appropriate training. It is organized
by position. Compliance Engineers, Pre-treatment Coordinators and Para-
Technical Specialists appear to be the three groups most dissatisfied with
their level of training. The one Pre-treatment Coordinator in the survey
claims that he/she has received no training at all. On the other hand, that
person also self-assessed as "HIGH" in all key knowledges and abilities. Two
of the three Para-technical Compliance Specialists believed they received "too
little" training, and one also states that he/she has received no training at
all. This self-report appears to be consistent with the assessed skill levels
for these staff members' knowledges and abilities, which were the lowest of
all respondents'. Finally, almost half of the Compliance Engineers claim that
they received "too little" training to properly conduct their responsibilit-
ies. Since there are four key knowledges where aggregate skill levels for
this position were either "a WASH" or "LOW", attention should be devoted to
assessing the potential impacts of further training on these areas.
The Phase II and III surveys allowed managers and employees to identify
those tasks/activities for which additional training might be necessary and
helpful. Exhibit 12 presents, by Division, the number of staff who desire
additional training for a particular task/activity. Within the WD, staff seem
most interested in additional training to increase effective performance for
identifying toxics problems and conducting toxicity tests. ESD staff, on the
other hand, are much more consistent in their desire for additional training
to increase effective performance across all tasks/activities, while some
respondents also desire additional training to be prepared for new work
assignments concerning POTW sludge analysis and overall monitoring strategies
due to the increasing emphasis on biomonitoring activities within Region V's
toxics management control strategies.
-------
111-25
EXHIBIT 11
Number of Respondents Receiving Appropriate Training by Position
"--^^^ Opinion of Receiving
"-^•^^Appropriate Training
Position ^^^-v^^^
DIVISION DIRECTOR
DEPUTY DIVISION DIRECTOR
BRANCH CHIEF
SECTION CHIEF
PRE-TREATMENT COORDINATOR
STANDARDS COORDINATOR
PERMIT WRITER
WATER QUALITY MODELER
COMPLIANCE MONITORING
SPECIALIST
COMPLIANCE ENGINEER
AMBIENT MONITORING
SPECIALIST
WATER QUALITY SPECIALIST
PARA-TECHNICAL COMPLIANCE
SPECIALIST
STATE GRANTS COORDINATOR
OTHER
TO A
LARGE
EXTENT
-
1
5
10
-
2
8
2
4
4
3
4
0
2
15
TO
SOME
EXTENT
—
--
1
7
--
1
9
••
7
5
4
7
0
4
9
TO A
LITTLE
EXTENT
—
--
~
~
~
«
1
1
«
8
1
«
2
2
4
NOT
AT
ALL
-
-
-
-
1
-
-
-
-
-
-
-
1
-
-
-------
111-26
EXHIBIT 12
NUMBER OF RESPONDENTS REQUESTING ADDITIONAL TRAINING
BY DIVISION AND CRITICAL TASK/ACTIVITY
""^-^^^^ Request for
--^^Additional Training
Task Activity ^-^^^
Identify Toxics Problems
Conduct Stream Surveys
Review State WQ Standards
Establish Permit Limits
Develop WQ-Based Standards
Coord. Pre-Treatment Programs
Conduct Toxicity Testing
Review Sediment Analysis
Review Bioaccum Studies
Calculate WLA
Develop Mixing Zone Policy
Review Fate/Transport Studies
Review Permit Appeals
Review Compl Monitoring
Results
Review Compl Eva) Inspections
Review ST WQ Mgmt Plans
Development
Develop Overall Mgmt Strategy
Develop Case Studies
POTW Sludge Analysis
CWA Requirements
Other
None of the Above
Water Division
58
37
41
51
43
36
44
44
45
36
32
40
42
49
44
45
48
39
34
40
6
7
Environmental
Services Division
23
23
14
11
18
16
24
22
22
14
12
17
10
20
16
13
19
13
15
14
4
5
-------
111-27
Some of this training can probably be best performed by Region V staff
members with demonstrated expertise in a given area. Possible approaches for
developing and delivering the requested training include:
— Participation in developing and delivering courses via
the EPA Institute;
-- Structuring and implementing focused "on-the-job"
training in areas where application of specific
technologies is highly dependent on specific situa-
tional factors (e.g., testing methods for toxics, such
as bioaccumulation studies, toxics water modeling,
etc.); and
— Developing seminars using in-house staff to keep
Region V staff members current with trends in program
policies, Clean Water Act requirements, legal issues
and procedures. These are all areas where gaps were
found consistently, whether data was arrayed against
positions, tasks, or simply the entire pool of
respondents in aggregate.
t Job Rotation is another effective technique for developing staff member
expertise in areas where it is critically weak, while offering the additional
benefit of broadening staff members' perspective vis-a-vis the various roles
and responsibilties of positions within Region V's water toxics program.
Region V has shown a willingness to detail staff members to positions in
state agencies as a means of technology transfer to those organizations which
are assuming increasing responsibility for water toxics control. This tech-
nique is viewed by Region V management as having been fairly successful in
accomplishing the technology transfer objective, but it was not reported to
have had measureable impact on improving competency in key knowledges and
abilities.
-------
111-28
For the latter objective to be met more effectively, it is preferable to
structure a job rotation program which has the explicit objective of enhancing
competency in a particular skill, or conversely, buttressing competency in a
key area where the current incumbents of the position are noticeably weak. To
accomplish this, possible approaches include:
— Detailing staff members who are weak in a given
knowledge or ability to a position whose members are
very strong in those specific knowledges or abilities;
and/or
— Detailing a staff member with an advanced level of
expertise in a knowledge or ability into a position
which is weak in the same essential knowledge.
Since Region V staff members appear to be strong in their levels of
expertise for four of the nine positions regarding future skill needs, job
rotation should be considered as an option for those two positions where
significant weaknesses appear to exist. Furthermore, that rotation should be
of weak staff members to positions whose incumbents are strong in the relevant
knowledges and abilities, since coverage in the two positions where that
appears to be the case (i.e., strong incumbents) is very limited'(e.g., only
one and two incumbents in those two positions, respectively).
Thus, it would appear to make more sense to detail Permit Writers (whose
skills are assessed as weak) to the Pre-Treatment Coordinator position (whose
skills are assessed as strong), since they share identical sets of "key
knowledges", and virtually identical sets of "key abilities". Water Quality
Specialist/Biologist rotation into the Standards Coordinator position might
also provide opportunities- to enchance specific "key knowledges" where the
former group is noticeably weak. Finally, Region V management should consider
a rotation of Para-Technical Compliance Specialists into either a Compliance
Monitoring Specialist or Compliance Engineer slot, as long as there is a clear
understanding that the role to be played by the "detailee" is one of
"apprentice to", not "substitute for", current occupants of those positions as
a means of developing the very weak skill levels of the Para-Technical
Compliance Specialists.
-------
111-29
• Specialized recruitment is potentially an effective approach to
buttressing staff member competence in critical knowledges and abilities where
slots are available. It is typically most appropriate when the nature of the
target knowledge or ability requires such a substantial amount of academic
training and/or professional experience to acquire that it would be imprac-
tical to attempt to bring current staff members up-to-speed in that area.
Possible knowledges where gaps exist, and which also appear to meet the above
criteria, are those of physical/chemical and biological principals, human
health effects, industrial processes, and toxicology. Such a strategy of
specialized recruitment is particularly appropriate, given the other condi-
tions, when the Region has an immediate need for skill in a certain area, and
no capability (however low) exists within the current staff; and finally,
t Details of staff members from other areas of the Water program, or
from other related Region V programs (e.g., Ground Water) where the detailees
possess expertise in critical knowledges or abilities, and where the use of
what is typically a "short- term" technique is warranted for consideration.
Examples of such cases include detailing an expert in toxics modeling to a
Water Quality Modeler position to provide some training for the other incum-
bents of that position. It would be equally appropriate to use staff member
"details" as a means of buttressing knowledge gaps in a particular position
while a targeted recruiting effort is underway. The essential characteristics
of this technique are that it is inherently a short-term solution, and it
presumes that there are staff members in other program areas who possess the
knowledge or ability which is missing among incumbents of the target
positions.
-------
APPENDIX A
SUPPORTING DOCUMENTATION FOR DATA ANALYSIS
-------
APPENDIX A-l
ACADEMIC DEGREES BY DIVISION AND FIELD OF STUDY
ACADEMIC BACKGROUND
BUS ACM BIO SCI CHEM SCI COMP I.S. EDUC ECON
TECH GEOLOGY
WD
ASSOCIATES
BACHELOR 5
MASTER 2
DOCTORATE
TOTAL 7
ESD WD
1 12
0 7
1
1 20
ESO WD
3 8
4 1
0 0
7 9
ESD WD
9
3
1
13
ESD WD
0
3
-
-
3
ESD WD
1 1
1 1
-
-
2 2
ESD WD
0 0
0 26
4
1
0 31
ESD WD
2
4 6
4 2
0
10 8
ESD
2
1
-
3
LAW NAT'L RES FHYS MATH PUB ADM PUB HEALTH OTHER TOTAL
WD
ASSOCIATES
BACHELOR
MASTER
DOCTORATE 1
TOTAL 1
ESD WD
9
8
0
0 17
ESD WD
1
2 2x
1 0
-
3 3
ESD WD
0 1
2 1
1 3
-
3 5
ESD WD
0
2
0 3
-
2 3
ESD WD
2
16
0 11
1
0 30
ESD WD
1 5
5 89
2 41
0 4
8 139
ESO
4
31
16
1
52
-------
J3M10
J39UI.6U3
UJ V)
8:
*
JSLJUSpS
J93ULDU3
n
O
CD
in
CN
u
0)
a
c
-------
a
UJ
a
&
o
_i
VJ
o
2
§
o
u
I
c
£
£
O
u r
a •
3 «
a r
c
o
o c
«• L
£ •)
3 -
a c
^-
E
•o
*«
C u
« —
•t a
u E
•> £
X*-
-C O
a x
M
— 0)
* U
1- c
3 3
*• O
• V)
a
X
B
o
c.
a
tf
z
B
o
a
<
z
4
(C
o
a
Z
<4
OD
«
o
L.
a
<
s
<
CD
5
O
r
a
^
z
^
tc
^
o
a
<
z
2
/I
/
"D /
C /
3 /
O /
O U /
- a> /
£ i / C
a> u / o
•o re / -
ID CD/ *•
U / —
< / O III
/ U O
/ o a
0
o
u
L
•r-
C
C
o
f
I/I
f
>
.*•
0
o
u
01
L
.*•
0
c
o
> •*-
*• Ifl
D —
a >
a, .-
D O
^>
•-
^-
-
**-
C
•^-
5
£
u
C
(Q
L
a
N
Cw
ry
w
l*>
4
—
r
u
r
O
*•
*>
u
0)
t/1
•^
4-
~
) L
: C
m «:
ft C
.*.
— °c
L
0) O
o
O'
— .
t_
o
in •»*
•0 IB
u C
IS —
C T3
C L.
ra o
- o
/) LJ
^
CM
M
L
01
«^
—
£
4w
—
e
4)
a
^~
^»
>,
-t-*
j
5 t-
0)
_ «-
; Q)
** "D
(0 O
$ 2
n
^>
in
•**
(V
u
0)
a> a
U ^1
1 u.
o
*j
-V
: C
O O
J 5
*-
IT
^
—
*"
i
- L
) £
C
- CJi
c
UJ
«»
»-
•*
*•»
^
2 **
"
,.
R
1 ••"
O
01
: a
(^
•-
_
co
V
-^ *v
it m
1C t
L —
u u
L/ 01
ic a
t ifl £
-
1C
U
••
C I -
C L' tf
Li C —
K S. — L
fM
•-
CM
—
in
^ u
C 0
10 ~
L CO
s c
' 01 T!
«&(_•«
L £ 01
"• I.
B O
C C Oj~ O
* U i/Mv/> O
"•
C"5
rs,
CM
-
*»
CM
1
^
a>
£
0
-------
>
a
K
wi
u.
o
Q
-J
UJ
•M
k.
s^
? i
v >
- 0
L O
• O
c c
•• £
a u
c »
tu t-
tft
u
E
O
c
o
o
UJ
c
o
V
c
u
3
•D
UJ
•0 u
C C
« »
u u
II I/I
3 •
a o
e «-
0 C
u i-
• o
u u
- c
E •
• •"•
L U
(J 1/1
• a>
o u
— c
a at
o —
— u
Q I/I
B
~ C
0
n a
O
i
^
X
5
<
*
o
£
a
^
X
£«
« L. unsvw
c ~
— M
n •—
3 C
ffi —
.|
4
•IP»B
•sossy
/
/
•o /
c /
3 /
O /
u *- /
- 0> /
£ .* / C
a u / o
•OH/ -
n ay *-
u / -
< / (J IB
/ (JO
/ 0 a
i
t
i
i
L.
O
u
e
t.
•f
O
c
o
-f
10
•f
>
o
•»
1
1
1
f
L
O
U
01
I.
MB
o
c
o
>* — •
*- 01
3 —
a >
01 f
o o
^
^>
^
(M
^
(b.
01
-~
£
(_>
£
U
C
n
ID
M
tfl
CN
(*>
fM
CM
1*.
0)
*-
£
U
C
o
~-
*d
u
01
^
—
4rf
;
1> c
E o
A' «^
(0 a
01 C
L. —
K "C
1 L-
01 0
L C
a u
«—
N
t.
o
IT ^
•C 0
u C
,5 .-
•c -o
; t
n o
— c
i/l U
M
W
n
n
»-
fM
^>
•»
f-
^
c
01
**
--
u
J
*•
•*-
E
~"
•-
•*
>>
t*
(0
D
3 u
ft>
L. —
^ Q)
" T3
a; a o
a Is s
N
•-
M
•"*
~.
f»)
•*
w
—
n
*•
u
o>
01 a
U 1/1
;
a u
o
4^
X ~
e c
0 O
-> z
-
CD
~
^»
V
j
L
tD 0)
(V
c
1 —
3 C
_; uj
^
^.
*»
'
—
*•
I
t*
1 4^
; tf
—
I (Q
) *•-
U
2 Q)
a
LO
*•
*—
n
n
x
^*
(0
M-
I —
(0
—
; u
a>
a
1/1
^,
-
-
- 9 **
: u «
c —
o —
-
-------
33UPI 101U03
I/)
HI
Q
LU
Q.
Q.
O-i
o
CJ
c
Q
Z
O
1/1
g
UJ
o
o
Q.
l/l
UJ
UJ
n
ipuejg
Ni
d| a
•n -3
a
0-
Vo
NJ
rvi
o o
01
o
B
4-t *-
C «
a> -
c c
O S> (0
L —
O-
0-
— u
>
-------
APPENDIX A-5
WEIGHTED RANKING OF CRITICAL TASKS/ACTIVITIES
BY TIME SPENT (BY DIVISION)
Water
Division
Identify Toxics Problems
Conduct Stream Surveys
Review State WQ Standards
Establish Permit Limits
Develop WQBL
Coordinate Pre-Treatment
Programs
Conduct Toxicity Tests
Conduct Sediment Analysis
Review Bioaccum Studies
Calculate WLA
Develop Mixing Zone Policy
Review Fate/Transport Studies
Review Permits Appeals
Review/Conduct Compliance
Monitoring
Review/Conduct Compliance
Evaluation Inspections
Work with States to Update
Management Plans
Negotiate Monitoring Plans
Develop Case Studies
POTW Sludge Analysis
Carry Out CWA Regulations
Other
None of the Above
*
1856 (1)
1478 (4)
1118 (9)
1200 (7)
882 (12)
808 (14)
978 (10)
1318 (5)
948 (11)
856 (13)
348 (20)
542 (16)
448 (19)
1554 (3)
1562 (2)
1124 (8)
1228 (6)
324 (21)
244 (22)
452 (18)
650 (15)
484 (7)
Environmental Services
Division
752 (5)
1018 (2)
578 (6)
120 (10)
384 (11)
90 (19)
770 (4)
956 (3)
1066 (1)
516 (9)
22 (20)
126 (17)
186 (14)
490 (10)
534 (7)
204 (12)
532 (8)
- - (21)
- - (2D
196 (13)
168 (15)
132 (16)
* Number in parenthesis is the rank of the task/activity relative to the
others in that column.
-------
aoieutpjooQ
'
M
>
!O
X '•
3
z o
'M H
a. i-
&
<
2
3
U.
U.
jaauiSuj
spaspuns
In
ipucjg
a 01 Daa KJ
UOISIAKI
rT
• t-
3 *
a
aiu
I
< .a
x
Q. U
O —
« o
> a
«
o
A-
N
Psi
in
v a
X C
a
jt —
c a.
a
J «
•o
o a
l 3
X
I. O
c «•'
« ;
u I
— c
« 91
o —
1(1
o
£
a
9
L
0
a
c
I.
9
£
O
O
<
9
r
s
a
-------
sjutjg
1^601099
-UOJ^AUJ
00
-0
CO
"0
IK Ma 13 1
Water Qua
d
l!
i!
(8«*
i>*
Q-0
°:
»5
>«
e
O
c
e
**
•
e
i.
>-
i
•
i.
Q.
* E
C •
c
•o o
L I.
o a.
o
U i«
•a- -
o c
a u
o —
e o
> a
«
o
> a
a
•o
aJa
gotl
Plans
«
>.
a
c
<
«
a
•o
3
3
O
a
3
a
«
a
u
o
a
9
r
0
o
z
-------
v>
*
o
-o
^
re
o
•o
|r
• •
• •
> o
5?
O -;
• O1
> a-
* 3
^
> •
I 3
C &
*• oi«
«• • — c
a -
• B
90.
I- !£
O
-------
as
(SI
I
O
•o
3
- o
u
?
<
o
UJ
Q.
a
K
U
a
n
r-
o
cs. <>
0
ci
•S3
as
tXr
O
Si
o
I/)
IU
ee
ec
tu
a
z
0
&£
I t
O
<-o
0
o
0
O
Q
-4
Ni
0
O
a
u
a
o
u
a
->u
!'*
"|5
0.
E
o •>
> K
a
I.
t s
• c
> •
o a
c >
e -
" m
m 3,
* O
L.
<- e
• •>
• »
e
a
T)
O
a
o
£
a
*
c
u
e
a
e
f.
At
TO
-------
A-l
.
e »•
32
e — «••
HS
.
e **
So
h-
X
a
UJ
Q.
0.
X
{ft
U
Q
U
UJ
-J
eg
e
in
K
kl
O
I
«rt
UJ
u.
o
a
UJ
8.S
•si-
ire
*1=
en
CM
CM
fO
CM
ro
CM
co
CM
O
XT-
r-
o
o
•o
o
o
a
L T3
a i.
«• a
a T3
* c
a
a ~
4>< (XI
a
•w xjr
t/> *<
Ravi
Qu
O
O
O
O
c
O
Davalop Watr Qua
Baaad-Standad
X
o
N
Q
o
- o
T5 0
w i.
o a
o
u
o
O
O
V)
O
TO
a a
i/)—
a
•" x
o-
fl
o
CN
O
C,
C
VJ
O
0
0
o
N-v
O
O
a u
o »j
• o!
> a.
ji
vlaw
Stud
G
o «
* 0
a a
a
> tr
Nil
O
O
rv
X.
<0
cv
O
Xj
X"
XJ|
o
xS.
-o
O
O
• •
O I
•D
law C
a
> o a
a
a
a
u
. a •>
»— c
"a ;
a
o -
POTW Sludga Ana
3
a
a
a
>
o
o
<
o
z
a
TOTAL
-------
32
CJ
CO
CM
•o
0
•c/
I
o
CO
c
C
0
O
Csl
O
O
c
CJ
o
Q
J
o
O
o
c
e
u
^)
o
0
r>
en
C
<
8
||
CSI
XJ
O
o
TK
VTi
Co
rv
O
•o
* u
32-C
11s
CO
•o
04
C
!
"0
O
0
\n
Co
CO
CM
o
O
O
o
O
•o
o
u
> r
a c
• o
QT3
o a
a •
> B
O
e K
c »•
3 U
O 3
I- O
C
O
u
-*
a
« =
a u
o -
a o
> a.
i -o
a 3
0 •
1 3
• 3
• c
> a
a a.
c >
* *«
« a x
• 3
~ o a
• *
- c
«• a
a -
9
•o
1^
>
a
a
>
o
2
<
I.
£
««
O
<
o
-------
A-I:
a
i
X Z
- lit
a x
z a
LU
a. _<
Q. JJ
< >
UJ
a
—
fl I/I
C 9
0 U
— C
i/l 4)
Ul L
9 9
0 C
l. O
a u
5 ai
o — c
1. 10 —
m i- E c
U) O L •-
10 O (0
— U. (-
U h-
O Ol
-> c
1 •»•
9 C
i '10
! ^
C h-
o
•A
"~ 4>
a c
c a
0 £
— c
4- a
(0 •*•
*> U)
O I/I
CT <
I/)
10 U
•*• 9
U —1
9 O
a u
i/i a
Ul
u C ui
'O 9 "~
i- S i. •-
0 C 0 (0
a ai -M
£ ••- 1)
a at a
t- Ifl
L /
o /
93 /
u /
c *• /
9 C /
••-9 /
L U) /
99 /
a u /
* a /
LU /
o /
~~ *"* /
!0 /
*• T3 /
9 *" /
E U / C
a- / o
O 9 / .-
— / i/l
9 / 0
Q / 0.
1
1
1
1
1
1
l_
0
u
9
L_
v
o
c
o
f
l/l
•*-
>
•»-
0
i '
«~H
c— 1
i— 1
l— 1
i — 1
L
0
4^
U
9
U
••-
0
c
o
•r-
i/i
~~
>
^~
0
X
4-J
3
a
9
Q
UD
^f
LO
t— 1
*±
CM
I4_
Q}
f
£
tj
£
U
c
A3
L
CD
04
r— 1
CO
r— 4
(^3
»—i
t— *
CM
n
4-
9
*-
£
U
C
0
*-
4>
u
9
i/l
O
O
0
o
o
o
L
o
4-»
10
c
••-
•o
L
0
O
(J
4^
c
9
C
4J
10
9
t_
>—
1
9
u
a.
•-'
CM
CM
O
CM
i — l
i.
O
4rf
(0
c
4-
•o
L
O
0
U
l/l
^
(— ^
•— H
rn
»— *
r— (
^t
,_,
L.
9
4>
--
U
3
4>*
—
£
L.
I
a
CO
CO
PO
o
i-H
o
I.
9
—
9
•o
O
S
X
4rf
->-
— '
10
3
O
L
9
4->
OJ
S
^
r— i
t—H
CO
i_H
r^
CM
01
c
•*-
l_
o
4rf
^>
c
o
Z -M
I/I
9 -r-
(J —
c a
n -
"- U
- 9
Q a
£ i/J
0
u
CO
CO
f— t
«^-
*— (
o
IO
CM
c
9
9
C
a
c
LU
9
Lj
C
!0
•*-
.
a
5
u
CO
^o
cy>
»— i
IT)
ro
01
c
L
O
4J
•^ 4>l
C «
O —
s -
4J *
C U
9 3)
— a
O V)
£
1
i
l
CO
CTv
CO
,—4
CO
CM
4^
I/I
^~
—
(0
••-
u
9
a
X
4^
^~
—
10
3
O
L
X
4*
to
3
T 1
CO
n
0
0
o
1
u
^
o
—-
.—
3.
£
O
O
—
a
j *-
••- ji
c -^
_^ —
u o
I -
K U
1 9
•o a
i- i/i
0
a
CO
p^.
r —
CM
U3
CM
L.
o
4rf
a
c
•*-
"O
L
O
0
o
U)
4*
C
(U
I*
o
41
4^
a
4^
1-0
^
ro
CM
VO
CM
r-H
o>
^-f.
(_
9
C
O
00
CO
^o
o
«— 1
in
i— <
r— t
O
r— i
Lf>
^O
ro
CM
j
^
^
o
-------
APPENDIX B
DOCUMENTATION OF PROCESS - REGION V
-------
B-l
I. INTRODUCTION
In May 1985, Water Program Managers from around the country gathered at
the Integrated Water Quality Management meeting and expressed their concern
about State and Federal staffing requirements for fully implementing water
quality-based toxics control programs. The Office of Water Regulations and
Standards (OWRS), in cooperation with the Office of Human Resources Management
(OHRM) and the Personnel Management Division (PMD) have initiated a series of
four human resource planning studies designed to address these concerns. The
purpose of these studies is to review and define Regional water toxics control
program work requirements, and to determine the quantity and types of skills
needed to implement these requirements in the future.
The first of these studies, involving Region I, has been completed by
McManis Associates, Inc. OWRS and OHRM have engaged American Management
Systems, Inc. (AMS) to complete the remaining three studies. OWRS/OHRM have
targeted the Region V water toxics control program to be the follow-up study
to the McManis effort. Region V was selected as the candidate for this study
because of its innovative approach to water toxics control and its primary
role of oversight responsibility concerning delegated State NPDES authority.
The objectives of the Region V study will be accomplished through a
four-phase effort:
• Document Region V's current processes for controlling water
toxicity;
t Define program activities for the purpose of unit pricing
(estimating the amount of staff time required to complete the
activities in the process);
0 Define Region V's current and future workforce
characteristics to fully implement post-BAT toxics management
processes; and
• Provide strategies for ensuring that Region V has the proper
quality of staff to execute its future program needs.
-------
B-2
We present 1n this report the results from the first phase of the Region
V study. This documentation phase focused on identifying Region V's current
management processes for overseeing State standards-to-permits processes for
toxic substances, and Region V initiated water toxics control functions. Key
Region V managers and line personnel were interviewed during this phase and
provided information on all related Region V activities.
Phase II of this study will define the Region V oversight program
functions and tasks, identify specific skills and abilities for future
oversight activities and estimate the level of effort, through unit pricing,
to implement the Region V oversight role. AMS will conduct in-depth
interviews with Region V managers to verify current processes and identify
future program trends and skill needs to meet Regional oversight
responsibilities.
Phase III of the study will identify, through a staff survey, the
current mix of knowledge, skills and abilities (KSA) for Region V
standards-to-permits oversight responsibilities and define which of those
capabilities can be applied to the future post-BAT toxics management
processes.
Finally, Phase IV will involve integrating the information from each of
the previously completed phases and identifying "gaps" between Region V's
future resource needs and Region V's currently available resources. The study
team will also examine strategies such as training programs, staff allocation
and development policies and recruitment alternatives in defining a possible
human resource strategy to ensure that Region V has a properly trained
workforce to implement oversight guidance in the years ahead.
II. PHASE I METHODOLOGY
The methodology used in the Region V study is a refinement of the one
used in Region I. Region V differs from Region I in that Region V does not
participate directly in the day-to-day standards-to-permits toxics process;
rather, the Region is involved in oversight and guidance activities to ensure
-------
B-3
that National and Regional policy is being implemented on the State level.
Consequently, some changes were made to the Region I interview guide to focus
the Region V interview process more on the nature of Region V's
responsibilities. For Phase I, less time was spent on defining the actual
toxics permitting process, than in Region I, and more time was devoted to
identifying Region V managerial actions as they related to a "generic" toxics
permitting process.
Implementation of Phase I began with the study team becoming involved in
detailed briefings and discussions with Headquarters staff concerning the
areas of standards development, permit writing and compliance monitoring. In
addition, the study team participated in document review and project strategy
meetings to enhance familiarization with post-BAT toxics control processes and
to clarify the project objectives with Region V representatives.
The study team visited the Region V office to conduct informal
interviews with key Region V personnel1 from the Water Management Division and
the Environmental Services Division. The objective of the interviews was to
allow the Region V personnel to present their interpretation and definition of
their oversight roles and responsibilities through informal discussions and
meetings. This approach allowed the study team to identify persons and
functions which are key to Region V water toxics management oversight and to
begin to discern future program changes and trends and their implications for
staffing.
Upon completion of the site visit, the study team began the
documentation of the functions, tasks and workflows pertaining to Region V
post-BAT toxics control management. A draft form of the documentation was
presented to EPA staff for their comment and input. Additional phone
interviews were conducted with selected Region V personnel to clarify issues
raised during the actual documentation process. A final version will be
forwarded to the Region V study participants for any additional detail or
commentary.
Appendix A contains a list of Region V interviews.
-------
B-4
III. CHANGING TRENDS AND OVERSIGHT RESPONSIBILITIES
Region V provides an interesting mix of current EPA toxics control
policy implementation and innovative water quality-based toxics control
development. For example, Region V has taken an aggressive approach to the
implementation of biomonitoring techniques in State permit writing and the
development of POTW pre-treatment policies to identify "indirect" polluters.
Consequently, there has been a shift in the skill and knowledge levels needed
in Region V to meet the increasing complexities of water quality-based toxics
control.
In order to assist EPA in identifying areas of important policy change
influencing workforce requirements, the project team has completed a
preliminary listing of the major trends and program directions that are likely
to occur in Region V. These eleven trends were compiled during the Phase I
site visit and will be used in the Phase II Interview guide as a basis for
identifying future workforce requirements. These trends are:
• The Region will increase emphasis on improving State
bio-assay capabilities for toxics;
• There will be greater emphasis on biological surveys to
assess toxics impacts;
t There will be increased Regional use of computers and
computer modeling; e.g., developing/assessing toxics data
bases and wasteload/TMDL allocation models;
• There will be an Increased Regional focus on identifying and
developing controls for complex toxic situations; e.g.,
chemical and/or organic interactions requiring more
sophisticated solution techniques;
• The Region will increase its emphasis on oversight of State
toxic sludge management activities; e.g., identification and
disposal of toxic sludges;
• Greater emphasis will be placed on health risk assessment;
• The Region's management role in pretreatment programs will
decrease as States assume program responsibilities;
-------
B-5
t The expected decrease in the number of "Federal Interest
CH1es" (from the perspective of the pretreatment program)
will enable the Region to shift its resources to oversight of
State pretreatment programs;
§ There will be increased emphasis on the technical aspects of
toxics compliance monitoring and on taking enforcement
actions against non-complying toxic dischargers;
t The Region will place greater emphasis on encouraging and
assisting States in improving their inspection and
enforcement capabilities for toxic dischargers; and, finally
t Greater demands will be placed on regional staff to serve as
expert witnesses and to speak at public and evidentiary
hearings.
IV. PHASE I OUTPUTS AND DOCUMENTATION
The Phase I fact-finding and analysis have been summarized in the
following sections of this document. In Section V, a narrative discussion is
presented of the Region V oversight responsibilities, by Division, Section and
Workgroup. The narrative discussion technique provided the study team greater
flexibility 1n describing the formal and Informal Region V oversight
activities. The generic toxics permitting process (as described in Exhibit 1)
presents the entire State standards-to-permits process and the specific roles
and responsibilities of WMD and ESD organizations within that process. Each
of the responsibilities discussed in the narrative is related to a specific
"stage" within the generic toxics permitting process, which is diagramed in
Exhibit 2 to provide a graphic overview of the entire process.
The Phase I site visit also brought to the study team's attention other
Regional programmatic activities which are related to water quality-based
toxics control management. For example, prior to the beginning of each fiscal
year, the Region is Involved in an annual program planning process with the
States. In Exhibit 3, a time chart is used to present the series of events
that occur during this process. Region V water quality-based toxics control
management activities also include the on-going development of new policies
and strategies among the Division's Sections and Workgroups. There are
currently eight major programs underway in Region V which deal with water
-------
B-6
quality-based toxics control issues. The study team has documented these
"other" management activities and identified the associated Section or
Workgroup involved in Exhibit 4.
V. OVERVIEW OF REGION V TOXICS CONTROL MANAGEMENT
EPA's Region V consists of six States: Indiana, Illinois, Michigan,
Minnesota, Ohio and Wisconsin. Each State has been delegated NPDES authority.
The EPA Region V office is primarily responsible for oversight activities
related to each of the States' standards-to-permits processes for toxic
substances, but is also carrying out water toxics control functions directly
(e.g., compliance and enforcement).
Region V also works very closely with the delegated States in planning
and implementing a broad mix of toxics control activities. Responsibility for
the Regional oversight activities is divided among the following:
Permits Section (Water Management Division);
Planning and Standards Section (WMD);
Compliance Monitoring/Enforcement Section (WMD);
Biomonitoring Workgroup (Environmental Sevices Division and WMD);
Quality Assurance Office (ESD); and
Central Regional Laboratory (ESD)
Each of these functional units participates in varying degrees in Regional
oversight activities. In addition, these functional areas share both
information and resources to ensure that the States' toxics
standards-to-permits processes are implemented. As a result, there is much
informal interaction between these groups in dealing with issues concerning
toxics permitting oversight. For example, Region V is playing an increasingly
aggressive role in assisting the States in performing biomonitoring activities.
To do this, Region V has formed a Biomonitoring Group which consists of members
of the Permits Section, Planning and Standards Section in WMD, and the
-------
B-7
Environmental and Water Monitoring Teams in ESD, whose primary function is to
develop guidelines and policy for State biomonitoring activity.
Exhibits 1 and 2 describe the roles and responsibilities of the key Region
V functional groups at the various stages of the States' "standards to permits
process". For example, the Region V Planning and Standards Section plays an
important role in providing guidance for States that are developing strategies
for modifying toxic water quality standards. The emphasis of Region V
oversight activities concerns the implementation of chemical-by-chemical
limits. However, the Region is also encouraging all States to develop
narrative standards for toxics control, and is assisting States in developing
procedures for implementing these narrative standards. The Permits Section of
Region V is involved in reviewing drafts of and approving all major toxics
permits before they are Issued by the States.
Once a permit is issued by a State, the Region provides oversight and
compliance monitoring support to help ensure that the permit parameters are not
being violated. The Region receives quarterly non-compliance reports from the
States concerning all major dischargers. From these reports, as well as its
own independent biomonitoring activities, the Region will formulate a mix of
compliance monitoring and enforcement activities to address serious instances
of permit violations. If these activities fail to bring a discharger into
compliance with the limits contained in its permit, the Region will then begin
additional actions, Including civil and criminal lawsuits against the
discharger. In all of the above activities, the Region works closely with the
States to effectively coordinate their efforts.
In addition to their oversight roles vis-a-vis the States' standards
setting and permitting processes, both WMD and ESD provide technical support
and guidance to the States in Region V. ESD conducts laboratory audits and
provides training to state personnel in sampling procedures, biomonitoring
techniques, toxlcity testing, etc. ESD staff members also provide direct
technical support to Region V's biomonitoring program.
The Region V office is also involved in an annual program planning process
with the States in which work programs are formulated that detail, among other
-------
B-8
activities, the specific toxic control related activities the States will
undertake during the year. Exhibit 3 provides an overview of this annual
program planning cycle. This process primarily involves providing planning
guidance to the States to assure that EPA priorities (including toxics) are
implemented in each State's permitting and standards-setting activities for the
coming year.
The Region has highlighted a number of toxic control program initiatives
that it plans to concentrate on for the coming year, in addition to its
oversight of the States' standards-to-permits processes. These include:
• Development of a Lake Michigan toxics strategy — a very
broadly-based effort which encompasses tasks like
implementing "free from" language in States' standards and
permits, revising water quality standards for sections of
Lake Michigan, targeting ESD's surveys to "pollutants of
concern", and including "pollutants of concern" in effluent
limits;
t Development of a Biomonitoring program -- which includes
focusing ESD's biomonitoring efforts on fish tissue
contamination, supporting development of biomonitoring
capabilities at both State and Regional levels, and reviewing
the results of the ongoing biomonitoring program for WQS
implications;
• Development of a Municipal Toxicant Strategy — an effort
which involves reviewing permits for anti-degradation issues,
working with ESO to develop a monitoring strategy that
supports the program's objectives, identifying toxic
discharges and developing data via toxicity testing and
biomonitoring surveys, and defining necessary pre-treatment
programs and auditing ongoing programs;
• Development of the Grand Calumet River Master Plan - which is
an ongoing project involving the following Region V
activities: developing WQS standards for Lake Michigan that
include toxic limits, conducting sediment studies, analyzing
the impacts of discharges on the Great Lakes, completing the
biomonitoring studies in the canal, implementing WLA's for
toxics, and ensuring that States include CSO limits in
permits for this area;
• Development of an Anti-Degradation Policy Program -- which
includes ensuring that all States have anti-degradation
language in their water quality standards, reviewing permits
-------
B-9
to Identify anti-degradation issues, reviewing models and
calculations, and ensuring that States implement procedures
to implement this policy;
Development of Combined Sewer Overflow Strategy -- a program
which involves assessing the impact of CSO on water quality,
ensuring that Regional guidance vis-a-vis 305(b) Reports
includes a paragraph on CSO, helping select dischargers for
CSO monitoring, ensuring that permits contain language
relavant to CSO control, and applying additional
pre-treatment controls to industrial user contributors;
Development of POTW Pre-Treatment Policy -- an ongoing
program which currently focuses on identifying indirect
dischargers, reviewing submitted program plans, reviewing
implementation reports, providing technical assistance to the
States, implementing removal credits and "local limits", and
reviewing industrial user variances; and
Development of Total Residual Chlorine Strategy -- an effort
which involves confirming criteria for TRC, establishing a
general state process, developing water quality-based TRC
limits, overseeing permit issuance vis-a-vis these limits,
and tracking compliance with TRC schedules.
The nature of these Region's, activities are described in more detail in
Exhibit 4 - Other Toxics Management Activities.
-------
o
K-
z
u.
- O
5 i/i
— t/i
£ UJ
* U
U o
a
a
u.
o
2
UJ
a:
UJ
X
—
^
—
(0
3 ffl
CT C
u 13
9 —
IB O
I i.
a
OID
C C
- 10
a
o a
— c
9 —
> I
9 9
•o —
>
C 9
IA C
9 —
—
10 -Q
— O
l/l >
—
9 0
£ >
*• C
^
01
C IA
•V- -p-
—
in c
— o
i» — ••
in oi in
18 9 (8
X O
13 I.
C ® ffl
18 £ «
— «- 01 Q
C Z
Oi •- 3
C in x ^
- u O
X — - C
9 « — O
- 0 0 —
> — 14. —
9 U
LOO) 9
*- £ I/I
C -
— — in
u c 13
D 9 — L
90. 18
> IA 9 13
— 9 U C
O L C IB
> IB -
C £ - t/»
— — IA
- - D
IA 2 IA C
— in IB
(8
C • 01
o in - C
— T3 IB —
Ol t- U C
9 IS — C
a 13 c a
C £ —
9 IB U O.
£ - 0
I- in *• •
4X
• u
in —
0 -Q *
- u O
a - t.
• D 0
— c u •*-
a. n o
a. - ». in
D 3
IA — L TJ
IA — « 9
9 — -0 u
o e c o
o 3 n L
i- 5- - a
a m
i- a.
Q 9 9 O
C - > —
— a — 9
C X - >
C IB 9
a 'D i- T3
— 9 u
a > IB o
O C -
M U
3 a O.D
o a o c
3 10 — a
C 9
- £ > •
— Q 9 IB
C 3 D -
O O U
U L in 9
£ 9 ~
£. IB I.
— in — u
O l/l
£ - U
0 «
3 C *~ **•
O — IB —
£ C3I 9 9
- c > a
— 10 in
-- £
in — —
9 O 0 IB •
— L — U IA
a - — T3
— C in E \-
l/l O — 9 10
U £ 13
1- X O C
— L — 10
9 O — IA —
£ «- L a in
- o
in — — 9
If! 9 L — lA
9 — Q. 9 9
U Ol X £
3 - » ~
CT • C 18 Ol
91-0 C
in a 9 - C
dec n 9
CO U E
o — L — 9
— 9 O 6 —
o > — i 9 a
3) 9 10 £ E
a D £ u -
1
u
X —
— X
— o
~ 4rf
flj
3 L.
a o
14.
L
i a
4M —
10 L
X 9
—
3 —
£ u
— u
a
0 U
— z.
9 (0
>
a, — ,
9
C 01
— X
X
9 O
I/I
3 13
9
0 >
o
IA in
9 m
— —
IB D
I/I
O
u Q
O
9 0
C -
10 IB
•3 13
- 10
2 t.
Ol 01
9
01 13
— —
a -
o c
— 10
9
> a
9 C
13 -
D
0 3
in -
— u
• c
m
— -in
in g
> 13 U
U C
can
0 "3 -
— cm
01 IB D
9-3
ff in in
i
x • - o
- - IA £ Ol
9 — IB O 1C
t. u I- E •• 9 —
3—99 L • !_ — 3
IA «C9T3 IB- — O O CiA
C O3>£3 C9 O - u — — •
9 —931— — «9£X L Z — — — in Ol
u u 9 u t- ». oimc c C.IB:
O 01CC9C — L — <4.v9O O E£ —
— C IB — > — — 3 — UEU «a —
— LIB lAU'C — — I-O BllA
(A — 3 £ IA 019 IA93— X 99
— U in • S -CT3 CCO£i— «.—
— 3U1^1O— C--^"" OCfl ^ 2 —
E 'OI09U1— omL — O « L O — Cu
L c .-QJ^ — 9OO — in U — — IB — 9 —
9 OX— > O — — *- ul. 9 3 fli-C
a u — — »- — 9 — — <9Ol£inCT >-O
— > o — tr— ci a c — 9 o 3 u
13 L — — U >OO — — — 13 i- (J £
9 O IB — 9 10 9 — £ — C Ol — C — C C U
— «-3OU £— Ol 9 C (8 — — IB a
U C" <0 — U — U L 9 E— U > ffl-E
9 in 4-— (B9£X a — O — — 9 9-
— 90lO)*-9 'D — O — — m — U ^J9
9 — C C O £ CO1IB9 — — — — U C C'B —
IA Ol — — *— IBCX£ 9EIBIAIB18 B —
OCU9 — — >l-tnL 2.—
C — 1. O u IAU— 99C10O13 I t.
O O 9 — C • 9OC'D OQ.— Ctn 9CO
B U — IB IA — — 9 C O — lA — — £
9 OCCum IB — — IB 'O — Q— UIO > m
U £OO39 — C £ OIBI/1O 99
c —oEmu t/ioEm £ c iu m — x i. w •a
IB 9OVIO £lB9 — O 9 — — IOC
- Em-— 9— — ElB >9iA
lA'D C IB *• — a 181/1 IT t i/l O 3 — — —
IA u — - o - c CT) m — CT Oim
1810 ai/1 — — 99O9 < JCO.O IAO9
•D O XI8C 9-C£ Q-C— W 3)--
— C — L— 39 X O — — Z«AO C9 — O
1010 9O3)O9 4.3— 9 I — X T3 O 'C 9
U— >i4-— u 9TjtAX 01— —O— —O*-
— 1/1 o i^9u ac9a c — • c > v/i£3
C Q in ID £ IB O— — — 01 9 m O — u
£9 O > *< inuT) Q. > C E — I- 9X10
9 10 — — <0 "O U 9Cl)3in — — I.— — a
l/l IB 01 I- A K OIBIA > IB — CT — C O — —
D 9"DO O L — — 9 9 — 9 U 18 — 10 O
C - - — ». a - ai/l-L 13OIC 3 3T3
189IB33 -» IB CO'O'D- 9CT
9 *-amo9 Q a'D£ c—Eccm U9L
X£ l/l 91-£ l/l CCIA01 — t- o (B O — Ct)0
9 U1C31— LU— IB— C O— Ul- a IB »-
— — 9 a— .* >• C >^— vA — O 9 O TJ
>— £ O — LO O C— L 9— UO»- — — — L ^^ aox— — E — tn « 99*-
— — I — 3 IB9mE 9£>'DU 9' Duo
>£ O — L m O 3(TIBO £ 9OC*- -3L
o— xtfioos L c o— — •O>—OIB >ma
L— — — o •»• — 01 C £ — D 9 — IB — — OC
Q. g a o — 18 -I IB— 13 inCOuai/1 U9a
in o 9 a c
»-U OCOOl/l O 9 a C — in ini8COIZ9 C -
»-- -OLE S £ 0£E .---18 £ 0-2.
(Ox u — • Q O 9 — L — 9 tna— — in 5
— o 01 — £ O< OIA— in X-. — -^ —
til— tnVDOS— C >4-i4. — •*-£> IB a — — IA — - 4J|A9
itrC — O OO C999C— 9>
— T3 L IB>£ L TJlA U > — IA C — 9 £ >^9
io9 09 - o -9-«a -oc-Ea 3^
CIA x£mc— — L— in— co— o— 9— CD
OO h-9OX — IB U IB — U O 3 U l/l > — « O9C
— a > u- c a®£3- — D u-au — u o
ao 3a— o — a m * a c 9 9 — a 9 010
«u C-139U E IA9E31O 9Ou3.u3> 9^in
aa otn9o:iB o O
- 0) U
1/1 o a
in
t>
X L.
— 18
L. — -Q 0
O — C Ol
— (o IB IB
m 3 — —
5 O i/l i/l
01
C
01 3)
9 31
-------
•o
4-
c
o
u
•-
4-
.*-
a
M-
£
X
UJ
Z
O
M
t-
0
z
3
U.
^
5
M
i/i
at
UJ
>
0
i/l
i/i
UJ
U
o
tr
Q.
u.
0
X
UJ
**
>
a
dJ
>
O
U
0
+i
+*
~^
E
a
3
in
i
9
«-
8
*/
1/1
£
a
3
0
L
£
in
C
a
_
a
a
c
L,
O
«-
-
0
E
o
.^
^
>t_
o
c
o
—
4- m
8 »•
4- L
C O
S Q
£ 5) •"-*
O L Q
— to
C. •"• UJ
E (0 ^^
- 3
C 9
9 C U
4- 8 —
a i «-
i/l E o
9
in in o
v. u
0 TJ C
~ C 8
— a i-
C 3
ox in
E - in
L <
C 01
0 - X
— L 4-
an
93 —
tr o" a
2
i O
•
9
£ C
— •< O
_ .^
« 4- o
C S 9
C £ (T
O *•
I- «! £ « 9
a » 4- £ a L
a- - TJ -
4-9 — 3
c — — 4- v> CT
O > £> « *- 9
— — 8 9 3 t-
« - C E 0
— U • «1 «l
> 8 O a £ 9
— in 4- c ~ 4-
oca — — a
0 C X*- I 4-
"O — — — g to
c 4- 4- 9 9 a
a u 9 4- E c i-
998 — O
£, a E — 9 •"
a in L i/i u c
— C 9 a 9 8 O
— m o £ i- —
— o i- 4- 4- 01
a T) £ a c »
c c i- a - o a
08 8 C U
— O 0
01 a • 4- — i_ £
9 C 1- C *- O 4-
a. — « 9 — »-
- 9 E 13 l-
»• a x at) c 9
O E — 8 O £
TJ m a cr c 4- —
9 U 9 "-• 8 9
in 13 i/i E
0 9 — T3 L 4-
a c •»- c -os
EC 8 in »- £
o a a i- c 4-
0 — C - 9 -
^ a •*• 9 4- i/i
E C - x 4-
9 9 O C 1- L. in •
9£UOX8ai.
4-4- ui m 4- a
4- 9 L 4-1 O 9
— a£a— (JUX
E c 4- a E g —
£ - L c *- a
0 T3 C X a — C
(_> L — I. a 9 U —
a o £ 9 E
— a a *- 94- ao
o 9 c a 4- m u
t- L — I. O £
4- 4- O 4- 4- E O
c in o a i/i — i-£
0 9 3 « J O ~
CJ 4- TJ ~ 9 »»-
a c £ c i- c
— i/i u — — a
a » i*- a E
Eag£O9OO
a £ £> 4- cr 4- i.
i/i 4- «.
— 9 •** 9 UI
— £ - ~ C £ 4- g
84-— a94—CU
C — 1 U E 8 C
OX O 9 9 *• 8
— in — u "O — «-
O) in g — — — 3m
94-4-83>in —
cr * a CT o c m
g 4- O 9 I- O V)
^Ei/i^-uaua
1
a
c
C 0
? **
8 9
X U
0 C
a i-
C 9
— £
T3 13
3 a
U TJ
c c
— 8
. X
in 4-
9 —
~- —
4- —
- a
~- —
4- —
U 9
s u
£> a
8 4-
— 8
T3
9
4- in
8 U
1/1 X
o
_
8 9
L
•*- 3
o in
c
I 9
9
-t- o m
> 4- 9
9 L
U *• 3
C T3
£ E u
01 a o
— — u
in 3 a
i- or
9 9 t)
> c
o T3 a
c
in a in
0) O
n in c
> — •"
o a o
L. 0 T)
a— —
0 3
c TJ a
O 0
— £ -
a 4^ a
4) 9 C
cr E o
O ^ jjw
£ a a
1 C
1
a
C 9 8
— TJ
4- — L.
c > o
9 O »•
E 1-
— a
a a -
E 9 u
— TJ 9
•*- »•
C 3 -
- a o
o
m 9
9 01 9
- 9 0
v £
— t- 0
_ **
—
u • in
8 T3 9
*. 9 —
4- a
O u E
898
in
_
9 O »- «!
~ U O L
a o
4^ 0 t- **
1/1 9 9 U
-Da
TJ a E i-
- E 3
a a c t-
O 9 £
£«-0
9 • TJ
•o »- •> c
— o 9 a
3 L.
O x 3 m
4- T) 4-
9 - 9 C
U L U 9
c a o E
a 9 L. 9
L 4- a L
3 C -
in — x 3
in TJ a
< 9 O 9
£ 4- L.
x ** in
4- 39
— 9 U i-
- L 3
8 3 »- *•
3 in o a
O C L
9 C 9
« — a
9 TJ 8 E
I- C £ 9
a a u «•
a
9 a c •
U C O 4-
a— in
4- C 9
C M O 4-
09 —
— 4- 4- U
a a -
9 in E «*-
. —
(V 1^
a —
c u
< 9
r-i
TJ in
c
a a
c
Ol —
£ •-
_ r
- 9
a E
E I
to _
u*i a
c
VI V
e
I- C
a
9 TJ
L. —
a a
O 0
VI **
_
a in
9
c —
G L.
— o
Ol 4-
9 a
cr i-
o
9 a
£ a
K —
1
—
8
c
0
—
*-
a
9 C
**
a
4- O
w C
a
t_
o •
n. in
9
in L
C 3
0 13
— ®
in u
in o
9 1.
in a
a -
C 0
C 4-
— c
8 O
L U
4-
>s
— 4-
a —
E -
L a
O 3
>»- 9 HI
•— 4*
o o c
> 4- 9
C E
9 L.
m c —
- C 3
o a
o in 9
in i. L
— 9
a a-
a
C X C
QUO
— 0 -
Ol 4- 01
989
or L a
o
9 a -o
£ a c
H - a
1
m
«-
-f-
E
i —
I.
0 U
I •-
X
0 0
4- 4-
m a
01 C
4- ~-
(S £
4- in
pyi —
—
9 £1
£ a
4~ 4-
m
in 9
a
L. L
— o
3 *-
a
9 VI
L 9 ••
i- in
in 3 9
** "O ^
- 9 3
E u —
— 0 U
- I- C
a-
in
u a 9
— > u
« — c
o 4- a
4- U 4-
9 in
•o •«- -
9 <4_ m
in 9 in
a a
£ a
C T)
X- C
« a a
- o
— — 4-
8 9 £
3 > O
a 9 —
13 in
L L
a c 9
4- — > --I
a o o
I > S
- s
14. C 8 —
0 O C
- 0 C
c a- o
o 9 a
— cr 9 ••
4- cr u
U £ 9
34-' l/l
TJ - m
o I *• in
L, -• 4-
.- x E -
C - i- E
— 9 9 L
in a 9
9 o a
£ — C
t- o — •
in
4-
— c
E « o
— 9 —
— — Ol
a 9
4- E cr
- 0
E U 9
L. £
g . 4-
a m
a •
a o c
C £ 0
— I/I —
a jt 4-
01.-
- 0 13
9 J -
> a
a a
TJ C C
— »*
C V.
— 0
4-
in — •—
9 c a
4. O 0
a E £
4- O VI
I/I — Jt
CO 1-
a ^ o
£ I
4- in
a *
0 O 9
4- £ — •
in >
9 .X 9
u i. cr
C 0
8 I ~
4- —
in TJ E
— C 1-
in a 9
in a
8 in
u —
— 8 8
8 C 3
u - C
-EC
C 9 <
£ in
u
9 13 in
4- 9 a
I. O
- 0 £
a M m
1- C i
9 O 1-
c a o
9 in x
a
— in
in a E
i. c 9
904-
». — m
14. O) X
O 9 to
cr
£ C
c a 9
033
- 0 -
a i. »-
a £ >4-
cr 4- uj
i
^3
9
~»
14.
~
4-
£
9
TJ
—
a
^.
a
in
^
9 in
f ^
9 C
E a
8 U
w —
a «
a o
4-
U
- 9
<4_ I/I
— o
U £
9 *<
a
m L
o
<*- *.
_
-^ in
in -'
_ j
g 4-
- 8
a ••
4- 1/1
1/1
9
0 £
9 X
u a
c
a -o
4- 9
in c
— w-
m u-
in a
a 13
- C
a 9
u 9
- a
c
£ 9
u >
a a
- £
U VI
O 4.
£ "^
E
TJ —
a —
m o
L C
9
»- T)
•- C
O 8
C
a
«-
a
i/i
g
£
**
4-
in
—
in
in
a
o
4-
U
9
a
L
a
£
U
in
.~
TJ
9
4-
O
L
a
**
4-
9
~
L.
9
a
i.
8
£
in
—
O •
in
00 *-
O l-
n o
i«_
a «-
9
3 C
in o
in —
— «-
u
X 9
8 -
E -
o
C u
3
— a
a -
g a
cr TJ
9 I/I
£ -
t- —
1
B-ll
E C
.- a>
_i e
a
•• o
, _ j
£ li Oi
>. > is
1 01 *•
-------
z
o
•*
^-
u
z
3
U.
4- 10
C K
O 01
0 >
^ o
- (A
l/>
v UJ
— O
O O
£ Q.
x
uj u.
O
a
LU
»4
>
Z
Lit
^
o
L
O
«- 9
>
m —
9 O
— 10
- 9
— L
>
- B
~ C
u a
a
x
4- t>
c —
9 "
E C
a 9
O T3
— —
9
> o
9 v
13
M
4- 4- •
- a E
E E 9
L 9 **
9 «•• n
a- x
a «
i*.
oca
o c
OI— —
c o ^
— 9 U
j: tr ra
U L
O 9
»• a -
L
4- £ U
C *• U
O 0
E C
— X
C 9
- in £
9 ~
•o ~
9 a IA
— !/)
O in
> x e
C — 3
— in to
in
in 9 —
- £
•*•< ^
> ra
-4. U
co —
0 C
- £ £
01 U U
9 (0 9
tr 9 ~
1
E
0 «
£ £
** «-
H- 4*
O L
9
3 «
a
~ 0
3 *•
O
in
C 9
(0 -
n
>/) *-
(0 1/1
vv
9
m £
C •"
a
— o
a *•
C 9
o to
— g .
- £ a
U *• 9
< L
— —
0 £ L
L in o
*• C
C B X
O L «-
—
u 13 -
- c u
* ra ra
0 *-
H *— >
E u
ra —
• L *•
x a —
LOU
a L 9
IA ID
9 O)
9 —
C L £
O ••
m — x
c
• o E
o e 9
L O —
10 — a
a fl) o
9 L
L 01 a
a c
— T3
— 09
- 01 *•
— c u
X O 9
a
> m in
- 3
c C m
0 O
— — ra
OI OI
9 9 O
tr t£ «-
i
9
£
4-
4*
IA
f
in
IA
10
_
— 4*
— C
x n
c —
O x
— O
a 4-
9
a —
a
9 £
£ 4-
**
L
• O
L *-
9
** *-
9 —
E E
L —
n
am
O
u 2
•4. (0
•*-
U OI
9 C
a —
1A £
IA
m —
in O
in re
9 4-
L IA
•D 9
ra C Q
"*" 2
o *-* —
W C
in 9 o
93
0 CT -
•Q 9 u
L 9
•3 l/l
L m
(0 - M
T3 9 t)
to ra n
4-~ T3
i/l l/l C
ra
3 £ ui
9 "D
*- 4- c
10 ra n
i/i a
9 C
ra ~ —
10 C
«_ - c
»•* 1/1 ra
_
tx
n
tt.
o
a
c
4-
<*.
ra •
L -a
3 9
4*
9 IA
£ 9
•>• 3
4- 9
4- L
^
—
9 a
in u
^ .^°
C
ra £
u
in 9
9 «•
(0 9
*• D
9 >
•D 0
C L
3 a
9 —
9 —
4- —
4- X
L O
g) '*•
a 01
9
O
9
9 £
4- 4-
ra
l/} 4*
^
Q £
L
•4- 0)
~ a
t
t.
D
*•>
^~
(. *
I C
—
*^ ^~
*• (jj
E T3
9 3
a 01
9 ~
4rf C
n 9
" 3
i/i —
^.
ra ».
9
o
«- u
—
9 *-
u —
C U
n 9
*• a
in in
-~-
in n
IA
ra «-
o
*
ra c
u o
— >_•
c -
£ ra
o —
«- n-
9 L
•o ra
~- ~
> o
O -v
L C
a o
o ~
IA ra
ra 9
a
— L
— 9
I C
C
o a
- c
a —
9 'O
tr L
n
o a
£ 9
>— t_
i
^^
Q
i/l
•o
C
o
Q
Z
*^
a
3
0
a
L
0
X
a
c
L
O
+;
V
c
0
E
o
^
o
o
4rf
9
U •
C "
B .-
*- E
IA L
- 9
IA a
in 9
a o £
4^
— ^.
a o i
u u
- a ra
c c L
£ - —
LI 4-
9 «- 0
4- a in
L —
L 13 ra
9
a. 9 -
*• £ -
O 4J —
X
- a
- c -a
— •*• c
x L n
3
•~- ^ in
D C
1/1 m ra •
uj 9 — in
- a 9
L 4- —
c — a v
> c —
l*- 4- L —
a u o **
~ a « u
in — ra
X C
c a o 9
o IA E £
— IA O <•*
*- ra —
u o o a
9 — C
l/l £* 9 — ^"«
4-4- 0
4- a to 9 i/i
— C - - UJ
E - t/i a ^
Li E
9 re x o 9
Q. 4- 9 U U
s^ L — —
9 > C t
9 C L O
C 3 IA
C - in 9
09—9 U
tn L — L c
L ra x a ra
9 O L
a o c L 3
£ o a o
— X — IA
ra 01 - <
c « » in
o 9 tr 9 >
— 4- 4- 4-
Oi B 9 ra —
9 *• £ <- —
a i/i >- i/) ra
3
i O
IA
L
9
4^
—
L
a x
c
— 4rf
L —
3 E
"O L
I
in a
c
ra -
— 14.
u ra
— L
C T3
£
U £
9 4-
4- —
X
a
10 C •
- O IA
— 4-
9 */ —
- ra E
n u L
4- — 9
i/> c a
3
O E L
*- E —
O 9
9 U £
O *•
C -
co ra o
4- £ 4-
U) L C
— o —
IA 1-
IA C «
10 — L
O
L C «-
9—9
»- E
n. 9 ra
o a L
ra ra
- a a
*"" C
I - Q
o uj
9 — *^ ^*
C X
C 01 X
0 T3 C L
IA C — O
L W *• 4*
9 n ra
a • v. L
IA O O
o o i. ra
^ — o _i
< - o
owe -
L — ra
- n c
re a c o
C 9 - —
o L a
- a -3 *
990:
9 9 >
a —
a o ra
9 E > L
£ « C -
K IA - C
9
l U
4-
•rf
E
L
9
x a
L
9 u
> *•
ra
a L
c •a
- 5
9 ~
U
c a
0 C
u —
L
- 3
X 13
C
c -o
O 9
in x
L O
9 —
a a
E
a 9
a
— if
9
9 —
~ a
» o
w> o
T3
0 0
- £
4-
9 9
u E
C
ra L
4- O
IA
— 1A
in —
in —
ra 3
— 9
ra L
— Q
C to
£ -
U
x ~
*• 3
O
L D
9 ra
Ife-
0 C
o
~ 4rf
— m
X 9
3
c a
o
— u
a —
9 *- •
a — 9
u a
990
£ a ~
t- in in
i
a 9
ra • —
ra
•<~ «*
— ra i/i
ra -
C 9 9
0 13 £
— 4-
a c
9—13
tr c ~
• ra »
9 in £
£ 9 L «•
*- a »-
•— L X
in u to 3
9 9 £ L
in a u o
X IA IA
— *- C
ra £ -3 —
c u
to — x x
£ £ L
- X .- !0
ra IA
3 "> £ IA
3 a 4- 9
< o u
L o a x
0 — C
1*- 4-
c ra IA
9 ra £ —
— — 4-
aa a
E 9 <
ra 9 L o
i/l U 3
C i/l <
ra m c
L 9
<- 3
— IA O L
— IA «• 9
a ^ c
in x c
x L ra •
o ~ ra E TJ
4- — in g
— IA L 4-
9 (0 9 ra ra
9 3 U - 3
a c E «
ra ra — >
— (A 9
9 a o
*- c u ra 9
ra — o D
- a - c
I/I 0 0 - C
— L ra
ra 9 a in u
> 9
•3 x a in in
C 13 C x 9
ra •** — IA
c *• ra x
9 - - C -
9 - ra »
«• 9 - C
«- « a L «
— ra IA —
E - 99
L VI 9 £ >
9 — 4- —
a 9 a -
£ E - ra
9 *•* ra o L
£ (A 3 «
•- IA 3 a
13 9 C E
*- — £ O O
— ra *- u u
i
X
L
— 10
— in
a 9
in —
L
£ _
— 3
a
3 C
9 —
_ ^
O U
> 3
C l/l
•3
IA • 9
L in •*'
x 9 ra
a 3 —
L 3- o
ra
£ C >
u £
IA U —
— 9 O
T3 «- C
£39
0 C L
L ra ra
m in
lA X 9
9 — L
- a 3
L 0 13
9
3 0 U
U-B 0
COL
— £ a
^
« 9 a
> E <
— O
9 L
U It 9
9 — £
L 3 «-
U
£ •- ra
a L £
i a~
9
c a L
0 C 3
— — (A
a c c
9 L 9
tr 9
u o
9 C ~
~ u -3
9
• lA —
lA — ' 3
9 m -
IA x ra
ra — £
u ra
C x
x ra —
9 —
«- 9 3
— ' >*-
u a ®
£ u
C «J ffl
M U) U
i
B-12
-------
*•.
•o
c
o
u
—
Arf
—
fl
£
X
HI
Z
O
^
U
2
u.
1-
cr
LU
>
o
i^
in
01
cr
UJ
>
O
•
£ u ill in
— — —
••9 — C X «-
C £ IB 3 »• —
9 ~ £ a— >
3 ~ > —
cr <4- 9 — A*
90 9 £ " u
L. x u «- u a
n- : C 3 a
9 a in B 9
B (A C 9 *- in
— a 9 9 £ £ 9
£ > U Ol £
" a— o a — K
— : O *• 9 M
E B 1. L.
L. in 9 "O 9 •
9 — I- C -M > B
a £ a — o c
i-o E o
£ — 9 ffl •*•
- • c e a c o
•M O L. Q9
- C — 9 9 — 00
9 9 oi a£ a
*- E 9 *- 9 B
a E cr ** cr "O
i/i u T3 co L in co
c i- o — -a
(8 T3 C T3 u- £ C
c 9 <* a
X a 9 9 fl -f
fl *• £ u- l/l
x a »• B o
c — 1/1 v c *• c
9 > o — in a
E 9 9 — O
3 L £ IA 9 S ffl
U «- l- T3 C
o - a — —
•o a £ — 3 • c
E - 3 Ol B C
•w u o u in a
— 0 fl 9 —
E u- - CO U Q.
I- C X L C O
9 — O a O L. 13 '—
a - a— a c Q
u - ~ ca s
•» o a 9 a 9 2
a o i " c «
l- 9 *• ^ CO ** C
T3 U — C 3 — O
— •o 3 a in E —
— «*- 9 O in L. *-
8 >«- 13 fl — — 9 u
— o c a a o. 9
«< 9 C " I/I
— — «• m o — —
c a c c — E « B
— c — L. a L. c TS
O 9 9 9 O L.
c — fl u cr a— a
CO Ol— C Ol T3
9 O • 9 O C
»- cr B u 9 £ a: a
OB"*' —
9 9 L. a 9 l/l
C £ U O " i«- £
O *» O l/l O -w "O
— i- in c
- 0 a*- B 9 X CO
9 *• C *• Ol £)
— 01 9 9 a CT
at: C E 9 •" 13 C
£9— 9Eina>" —
O "C ** 9 *•* 9 C
UL-1--9UT3 C
8 — O — U 3 3 a
ClEaE— T3 — —
OL.UBI--WCU a
ao9— 9OOC
3*-at3acu— •
C 13
O 9
01 8
9 —
cr 3 *•
u u
9 — a
£ a *•
•H U
01
• B C
-a —
— X X
E c
i. •*-• a
9 — a
a E E
— o
9 — U
£ U
4- 9 a
£
3 ** £
X **
T3 O
9 £ 13
•o c
3 • a
— L. —
u a
c - o
- 3 E
U 9
c - s
9 *•
9 1- C
fl a o
a —
a c a
£ — 3
*• 13 a
- c >
E a uj
— *•• x
— M
u E -
* — a
O 3
•• in O
-~ c <~
CO ** 9
o **
x L a
~ o x
T3 in
9 in •
B — 9
a B *-
fl a a
fl *•
X l/l
*- a
- £ 9
a *•
3 9
a- 01
a c
L 3 —
9 - C
w a —
a > E
X 9 CB
X
a — 9
K- — X
- I CO
i
0
£
. «*
^
^ .
E —
— _j
f
9 —
£
«* B
•O
*- O
O £
C E
9
E C
a o
0 -
9 a
9 Q
•o -
9 <
£
*. 13
L O
0 _l
9
B **
9 III
L. IB
3 X
•o
9 a •
U C B
O — 9
LBV.
a 3 3
13
*- 9 U
a *• o
~ a L.
i/i — a
3
9 U <
£ — — J
** a 5
u
X B
9 9 •
> a *.
9 B
L in «-
»• i/i
— —
- E 9
- - £
X — «*
,—»
C X Z Q
O *• 9 Z
- - — x
01- > ^
9 a o>
cr 3 c c
a o
9 — •*»
£ L — ~
*• 9 — U
*• X 9
• a l/l
— x c
•w O B
9 C — *•
9 9 O —
£ £ 9 E
B X cr u
9
a.
•
B
** a
.^
E 9
999
a- -
a a
= e x
9 0
U U —
— 9
•w B 9
0 t. £
C 9
U E 9
— 9 £
- S -
fl
3 *_ *•
a **- a
i a £
4) A« ^
L in
a 9
: — l-
CC 3
- C B
- 0 C
8-9
Ol
*• 9 O
o cr »•
X • in
9 t, *•
— a —
> - E
93 —
L U —
9 w w
£ L C
*• B 9
a 3
in —
9 C »-
*rf t-l !«.
a 9
c
— . —
13 B -
L 9 a
0 «-
o a *.
u •• o
i/i
C X
O 9 9
— £ —
*. « >
U 9
9 E 1.
I/I O
I- 9
tfl »*- C
w — •
— • ^ —
£99
I- > 'O
9 — —
a 9 3
U 01
B 9
L —
c a
O 9 u
— L —
Ol 8 L,
9 C
cr £ 01
U 9
£ £ B
1- X u
1
u
C
a
«B
^ _
o a*-
*. E ».
o a
B U <-
- c
9 •
~- C 9
9 O £
£ - ~
a ~
- a c
a E o
a u
0 B
*- i*. *J
- C C
E - 9
i- £
9 x E
— u
9 —
£ — Ol
*• u C
a —
9 «- a
C 0
£ a 9
a *• >
« a 9
9 13 V
C
— a —
— u
x — a
E *•
c 9 a
0 £ T3
— u
Ol —
9 — a
cr — c
a o
9 —
£ B 01
— IS
9 cr
. —
C > T3
O 9 C
— L. a
*•
•— O 9
•Q fl *•
T3 - a
a a *•
i/i
C C
»• O 13
— C
a a
• 9
« a B
9 —
C 9 I.
— £ O
- i- a
9 9
•o • i-
— 01
3 C C
O— O
13 -
X— «- •
*- — u *-
— in 9 —
- a a E
a u B i-
3 a c 9
fffl - a
t^.
o
c
1-1 X
9
- 9
• > B
B 9 9
*- l- £
— *•
£ -
— a L
— CO
O t-
*J v-
P A ffl
i. cr —
9 a
a c 9
— **
13 B
9 *• L.
B 01 w
O — B
a B
O B 9
LOU
a c
o o
O i- —
c -
- -o a
X 9 E
9 E O
— L, U
> 0
9 •*- a
L. O
O —
C B 0
— • — >
B 9
B 13
9 9
*• L, 0
8 CO »•
*rf
l>0 B "O
a c
930
£ 0
w I. •
O) •-
O —
-IE
9 L
9—9
u > a
C 9
0 L. «-
— >*-
M 9 a
- 13 L,
B - B
B X
> **
0 — -
l. 0 E
a -
• —
C B
O 9 CD
— BO
CB a J •
9 U B
cr u —
9 — —
9 E * E
£ 0 O —
1- B -w —
1
_
a
c
o
—
w
in —
a •a
£ 13
a
**
»- x
i_
m a
i m
3 in
in u
— 9
C
B
B 9
3 13
U —
i/l >
— O
•a u
a
—
— in
— 9
X w
a
c -
O I/I
—
Ol 9
9 £
cr »•
9 - •
£ a B
•" £ C
- O
• —
X *•< *-
9 in B
— 99
> 3 3
9 CT CT
L o
l- 9
*• B
— X 9
E a £
L. E -
9
a °o 9
c >
-t O
a B B
L 9 9
"O *J l_
a
9 »• O
£ l/l ~
4-1
9 a
»*-£**
O - 8
TJ
C £
O •* L
— — o
<- X
9 C
- 13 0
a 9 —
E — w
o ». a
o - £
«* u
ceo
O 5J **-
a -a c
^ -r- f
I
^
** «rf
1 «^
(. £
ID L 9 --^
a c «- ^
a « u.
« - > c
£ « ^ O (8
** r U.
*- ^ ^ o
^ ^ —
c • a m -
a u L E
c c — —
9 3 S — 9
a « 3 a 9
*•• X 9 U_ D
i/i e cc
— 9 •
9 C( 9 '_' 9
£ r £ C -
•• - a fl
"c — a
£ C »- i. ••
- c - co a
- > 9
I * • U
3 B *• O
B C C C S
C - 0 9
o •c - .. »-
- C - 9 -
w e a 14.
a *• — «. T3
- « - - c
*• L. 3 O B
O « 3
O ~ 9 X C
9 C C - 0
C 3
0 g a *•
C — B •• B
- £ 9 C 9
£ 9 3
9 — — £ T
-a a
a — ar C
a *• c c —
— C — 3
U 9 L U. B
— «^ 3 *^ w
- 0 0 -
L. a BE
a 9 —
ar • u -
- 9 C
- o o a ~
— B *• t. S
x o a L
O C > 9
c «• a
o u *•
- «l 9
O « - £ £
9 3 fl L ~
cr « 3 9
B a a x
9 — 9
£ i- a-
«• L. O O >
O n. - «
.— , it.
x e 9 >
l. E - 9 -
a fl 13 -
B C CO —
B O — 2 X
9 — -
U 9 B C
9 « > 9 O
c - a 9 -
B — B C5 9
< £ — a a
i
—
9
>
9
—
9
U
c
8
—
l.
a
>
9
*«
8
—
l.
a
o
L-
a
a
B
w
- Ol C
a o c 9
c B a o
9—9 0
Ol £ £ 0
** ** U
9 U —
£ Ol — 9 -
*•> c •— *•* o
c 3 ai/i
a Q x
a 9 c
c £ a
o • »- "
— +•{/> O
3! — 9 », *.
9 E 3 O
cr i- O" in
99X9
9 a I- w B
£ - C
*- 9 X •— O
£ a — a
• *• E fl B ••
9 — 9 fl
9 «- U B L. 9
~ 0 - C T3
*• — 0 C 3
- B fl a 9 -
£ w 3 B — U
L c a 9 - c
99 L — —
a — — ^
C CB 9 X X
9 O <- L ~
£ U 9 *•* a —
«- C O >
9 9 fl — —
• £ Ol — 9 «-
— *- > U
c x w 9 a
9 C £ - -0
£ O *" B
£ • O "~
O w 1- 9 B £
U C O D - -
9^88
u E "O E Oi
-EC - C
— o CB B in —
fl u — 3 L
^ CD ^3
a o 01 - ~ 13
— ~ fl 9
l_ *- 9 *- 9
O £ — 3 a —
i- u 6 ff " O
— L 9 l/l L
•3 £ cs L
9 x a 9 -
3 a £ a
fl C « i- C
B — £ £ O
— ~ u • —
B 3 in a
B X k, B fl 9
— 8 9 9 CT
•O £ *• u
w t- — O
— O — 1-9
E c-5 9 a £
L • t-
99 • 31 9
a > T3 c £
a o — *• •
9 £ - - 13
«• 0 9 9 U >
- a E 3 -
C - tJ 9
9 fl X C (J
£381-09
s at3 o o i-
B-13
X
31
a
9
Ol
a
o
•z.
a ^
i u 9
Q a
fl
3
a.
-------
•o
c
o
u
j3
£
1C
11 1
OVERSIGHT FUNCTION
set Ion (WMD)
(/)
LU in
0 I
a IB
a o
c
II M
OVERVIEW Ol
• Planning and Stj
£
**
a
c
•D
Al
1 ved In re-opening negotiations with the permltta*
f variances and other points of contention raised
0 O •
> n
C 9 O
- 3 — -»
IA L Q
909 X
s — a. i
- The Region ma^
concerning th«
pub) 1c comment
• Permits Section
m
• 9 *•
*• U L • 3 « C •
IB — 9 ** £ m£ in *« o £
l/l fl *• E — „ .^ -g g „ 8 OB 9C
3X9LX9 C *• D 9 — L B £ *• »- *• 3 — —
^ 9 Q. — — 9 £ X *- — 9 U>9 U ** U O ** — — — B
c £ i L - a «> - ~ -IE*- coa — 9 c L. > c -
fl~99B99L *< > L in BL «-LL— 3 • t OOin
L£— £9999 C 99 9 — a 9 -O— 9 - 3 O L — -
-XO.****>-£L*-> 9 O Q 3 U — £ L 'O.C irtC a *- Irt
OOOC~3-"- 3 *• ff C a C ~ BL L-C IBin
C£99 B9O CT B 9 BEO — 9 T3 *• 9LO — Z IB •
— £ E M • £ - in 9 L L — O — O U O— O >B— '- in
LS"O»9*«9 9 m«* — U 31 C •• L O C 9 *- — 'DO*-
*- B 9 t- B X B £ 3 3 in — E • O) CC L a C £ B *- C ** B 9
— 3 C M *•*•*< o m a m ~ o o C 39 B LI — — x c C'OE
C— — "U — (/IMl/l*- — u 9 — 9 "O L ino— L9 O— 99
OIBL9 B£ 9 9 HI *< i £ B c — *• — 9BE — « i L
Z>3>*'9£9«-»' *-£OO 31BUt-'D G tJ S — — 3 0> C « —
9 T: — — C £ — L B — "C C — S CO — X— O*-U 0> O B 3
9 9 E «< C »• X O *- — — OL BC *• B U U LCD a— CT
B *-La*-O— 39 9£S9 IB L99O L oa - — — £CT
— in** 9U £T3£ 0> O! O *- — — OLa C>B *-O'O
a-E>£- -OB OOX L— - — o C£>£ — 9 -£-B
OL9£-D£»C COB *• fl 13 — — — C 98 — in
U9a*'L*'*'*'— B99— £ O>«9 139O'O CC. 9 £ttX9
axBB*-o a>*- oi*'£u£ c a-o — c IB L
9 9B£X*-9C9 • BC — O — « O *• 2 > O O 9C— — — E 3
£L££**LB— 3 ^9£9 inC9L O£>9> £ — > £< 'D
*-O" O£rC L£°O L£BO)C LQ1B *-LO u — C 9
—,«»«_*.»«— O*-C— 99 C— S'O 3L — LOU
£(B'0*'9 (JO** U 9> >LOin— jt9»OO O"Oa * U — O
•-ECBLTJCCTDC U-£9 OBC*-LT3 u *- — «• C O«0>L
— B*-O1CL9 O B'C-*' — — O 9 BM1 — *- X *-9®a
-C UL»- CXT3C 9 C 0 — • 3 — « -9E IB Ol
CSO9«LC3B— B S — B DO CO 9CJ 9 Bin • C9C
O — £C9OU«-— — 3 — — 9 O> ^9 U — 9 C M *.— £••-
— xo^Oi-ucoo— £fcOin >*->*-£C — L • o aLOin o KL
B-^QC(fl**91*-U9 (09 C LU"CE9 C in — a 9 3U a)*- *^
C>*-0-O£C 9£C9 a— Lutfl L— £ O9O «B- —
— 9 9 C 9 9*-O L OE *-C9C— a LO' 9*-ITL 3*-*-C
•OL£Ol/>9«l£ — 0— E C — — aB O9CH f a B l/l — O
L *-E 0 (B *• »- 0> O-tSO OU — C OC a- 3 B « 9 O E E
O— E — C 9 —9 *• 9U — 9 « C — O *•— LC *-«£CS 99— O
o— EOB9LO o: mo: cna99a— L^DB— 1/1 • «• c £>£ — —
U— OOCLS*- 9L U 9U)<-££CS'» CB99L U — *• O
XL OL • ~a — 99— a BXO9 Q O93£B BO-" 'D 9
C »- — — 3UT3T3C flt:£— *<*• ua S — £ in 9 LT3— OIO£O1
— IBCBU— C9B B— **J3 9 — */1 in J O MX£ oaBL u*-*-C
CinCBCtOS Cin 3 £E CC9 — 9 X— L «• »• x C -
•o-'-oao— a«9 3C-a •• L 9 o — £ IXL « « «- n secsc
C— C— U u « (I « OC «£— *• C BC— « LCU«< E'JCL
O *< 9 « • 9 9 — B 9UO£ -a*-*-m O 9— B*-O 9 9 — — EC— 9
— OE — £oaL ~ L — O • T3 U9- — £*• C£ *" E — E OB*-U
UI/>OT3 *• O— OSO> 3£»- B— U 9CT3 9OE9 in9O
i/iin i—oc *•£ oo*'£*' in xci/ia 1/1 o — c > o 9u — in 9
•Dinx (- B « — ** — 9 — *• u — ** 9 u a>L9 B> 9 m— c
UIL3C T3 XE OKZM 9 BXE — M 399 B 9X£ — B a O
*. ffl O fl • BBLC '9- O *- C £ — 9 O »- TD u « — 'O O — *• " B E —
£C>U99— aim £ 9 9 ML u IB -BO-3 9~Ba Z C. (0 B
LB9C — £LO 1C 'O «• £ C O9OO99 T3 S U m «-— C S auCE
9*^LB*'*>'flr09*'L C U9OI L — t*-ua C U1*- C9 -£3— *-* B — — L
•B-E 9U —
9— a99**-B**9mC 9E*- 9 9 0) C — ' O 3V "9B> 3)*, — ~- B — C ^
CrCLOLM l/l — 3 O £ L — £ L a C O C — L C l/l£LLT) dl/l > in —B —
CO— 9 — - U— -9EuO — - — B a — «-9«C 9— «- CBT3>
9MU*'*'*'— 99«OI a L — i*. BLO U C 9 C*-3 99m*- — 9 *• — O
£— COCB— ££— 9 »- 9£9 O 9 O — — C £O9CO £CBU £ £93L
i-a. — z— inxt-^ucc —saxa L^a^CB B K *• o— fl t- «• u IB L awcta
9 — £ 9 — 9
i i •xCB'ouaai i a i
•*- O £ C 9 a
B-14
•o
c
B
9 Ol C
U C 9
C -
IB L
— O
a -
s c
o o c *•
O Ol
-------
^~,
•Q
.
4>
C
o
u
*""*
_
^J
— •
a
£
K
UJ
Z
O
^
u
z
3
U.
H-
ifl
Z
UJ
I/I
t/)
UJ
u
o
a
u.
o
X
UJ
M
>
Z
UJ
Q
5
3
C
O
V
*rf
u
0)
(/I
+s
£
9
E
9
U
O
c
UJ
•s.
a
c
L.
O
—
C
o
s
9
U
c
a
_
a
E
0
o
•
ie States regarding
ielops an
:ant non-compliance
ite- inl t lat ed action
actions that the
i on dischargers Mhos
id tha State Mater
.L. f W TO D W
«- 9 — *•* 9 9 **
T3 »- Ifl £ in 8
E - ~ 3 -
o »- c o o o
i- »• a c 13 o —
t a - c *• >
•- » E 8
~ in o C 9
in c £ c o >
*- - - Z L — 8
L a 9 a £
o c g u o g
Q. 0 L 0 C Z O
9 — a *- O £
z a u 9 z
9 0 T3 £
g z £ c •*- *• "0
U Z 8 O £
C ~ - 8
a • i/i in *•
— « L in ^ in in
- u 9 L c — •"
Q. g a g is — —
6 01 i- *• «• E
o u a t. 3 « —
u a £ a — — —
1 £ U 3 — £
c u in a o ~ x
o in — a »•
r — ts 9 01 —
•o > 9 c o
X 9 — £ — —
— i. in in +> a x
L O O U O O
g ••-) £ g M — *•
** is *- u 9 g
u E u -a > *•
a x 3 3 9 c
3 — i»- I/I — T3 X
O — — U 3
^ a •« o c c -
C z — - n-
Z **• X ** "4-
Z — L. I/I •
O in o — £ g
3 o *- — g —
in *^ ** ^ o
9 a I/I 9 8 £ •
>•*•*: *- £ *> Z Wl
— in 4-1 •*• h- "D
g o E 9 x L
u o — — > v- a
g u _i — • is — B
u c — £ u c
a in *« x 98
c— c ••- is x a *•
o— oEzamui
- a- L i. E
a E " 9 9 MX
9 O a Q. "O in****
z u g c 9 — —
L) .C ^ 4-" C
g g x *- A L a
££uj^~ in** g 3
K •• : X — l/l a CT
1
ill) vary each
,e ac t 1 v 1 t 1 es and
I n a g Ivan year ,
e mon 1 tor 1 ng
f m u
» C
m £ • a
g ~ x-
— +* —
- u I E
> 3 O O
- -0 - 0
- C L.
u o a*.
a u o
8
a o in
C *• 9 'D
J3 C
!_ g —
o - o jc
4- a 4-
- a o
c - « c
0 — L —
E a 9 x
> 13 O
ia- —
u in —
C in C O
a g o H-
— o u
- L 9
a 3 c £
E O O *.
o in —
u 9 a H-
L 9 O
in z
*- X
> o g —
£ E
C - *•
o g a
- > £
ague
Z £
•*- £ 9
o »• in >
E -
x C 9 O
— O - >
E a c
a o —
13 C L
C - a in
a -o -
c *•
x g o c i/i
La o 9
3 g g — —
** 'D a a •*•'
a x g —
c • •- z >
g a 9 g **
£ 9 £ £ O
1- x •• *• B
1
'es approximately
ite Mater treatment
Itorlng Report*).
S IN ™~
- a c
o z o
> 2
C T3
— C 9
a a
£ 1.
o — «
- - £
*• a u
u »- 0
g *- —
a 3 o
in o •—
c
— in •
in *• z
- c s
£ a a
K —
Q.T)
C
.. g Q
^~* £
C *• «
O v
— ». 8
»• 0 D
U
g C a
a o c
in — —
c *• -
"- u a
9 E
c a s
o ie «
— c
*. - a
a c
3 « -
*
IB ^ 9
UJ 1 >
C 9
9 O L
U
C *- TJ
8 0 C
— M
Q X ti
E a g
O TD «l
U 111
^ g g
9 U
— L 0
UJ £ L
U *• Q.
1
1
C
9 9
E 3
a — jt
»- o
X 9 Z
£
« — O
a c*3
«1 C l
« - (O
C t- —
X
E X •)
9 £ 9
"a a
E g -
The Regional Inspector 1
the inspector M| 1 1 sampl
This process usually
in
c g
•• o «
'—' — in
c *• g
o — u
— 13 0
~ -O L
u a a
x
a c «-
in — c
c a
3 a
a a
C 9
- — *•
c i r
a -
Ifl 9
£ *•
g *• c
U 9
C in 3
a a —
— **-
- in n.
a g g
E L.
o 3 g
U T3 £
^ g */ .
u in
— O T3 X
i/i L c a
u a e 13
i
i
•ill sample the final
ler toxic substances
Ives b 1 omon 1 t or 1 ng
ite ef f 1 uen t
r Toxics): The Region >
t parameters and any otl
e Inspection often 1nvol
ken to run tests for aci
o — > a
t E - *•
L in
C X C 9
o a 9 L
— *• 8
*• • c
u in — in
u *. i g
a c 9 —
m a u Q.
c i- L e
— 3 3 a
- o in
a— in
C 0 9 £1
- a L a
a x g a
£** r
+* L,
i/l u u
O —
9 — • £
U L L Z
c a a
a g c
— L a — •
- o a
a*- a «
E g •
O *• X— X
U C 8 ~ *<
~- g £
3 > U
I «• — —
— *. a *• x
l/l »- £ U O
O 9 •" 9 *•
1
1
tailed evaluation
lose of this Inspec-
1 ng process .
9 L L
D 3 0
8 —
9 C
« £ 0
~ i- £
U 1
3 »-
T3 • -
C 9 9
O 9 «
U *•
*< *
C — -
0 E 9
— L g
a 9 *•
g a *•
a —
9 E
X £ L
£ *• 9
t- a
X
a g
£
^ "D **
in 9
C 1/1 <»-
0 3 O
—
*• m x
u ^ u
g o a
a£ 3
in ~ cr
C X 9
- E T3
8
~ a
— C 9
TD ••" £
< Q.
E x
g 8 H-
u tn —
C L
a x g
E t >
L O
o *• o
»- a *•
L W
x O in
a a -
— a
- c
»- o
< <*- —
a o »-
i
i
o
8
Z
o —
g 9
> L
9
•0 X
8
— D
— O
z n
c a
o
In compliance, the Regi
cement personnel Mill dc
** L
0 O
c •*-
c
i/i g
— •
—
9 8
a c
~ 0
*•> —
— a
E 9
u z
9
a
IS C
o
£ U
-*•* <
x —
C (B «-
ao «-
in —
— 9 C
»- n E
ifl <
c g -
8 £ 8
— *• L
a g
at:
c c g
0 — u.
- i ^
*• o
U — l.
< - 9
8 t3
g L
in g o
c «•
o a o>
a ~ o
in tn o
9
cy ffi (B
£
— *- g
a 3
L o in
x *• in
T3 -
g ~
u. c c
9 8
8 m u
a a c
o c o
g g a
> fl g
9 Z
•D C
O 9
•Q — £
C *• «-
^ •
9 o in
g — —
*-• > —
*• 8
*• >*-•*-
E o
L *-
g g a
a u £
g *>
£ 0 «-
.. C -
a a
u in
U. L
O • 3
E o
£ X u
z o a
L L
CO.!
O T3
— XX
a £ u.
x -
/v ^
nee and to provide the F
hedule for abatement of
Criminal proceedings ir
8 U T3
— in C
— a
a-o
E C -
08-
U >
X —
o a u
*• x
c •• c
- s -
L a
g „ g
E * a
o
u a c
a
o T; u
** c
9 3
9 E - •
*• g a L
«- - g o
— a z •<
E o a
L L g -
9 O.£ O
a - -
9 >
9 £ •
£ - " g
4- L £
14. 0 ~
in o in
X I -
L g L m
— u c
0* «• m a
« o a a
L c - a
B-15
-------
o
cc
o
u
UJ
X I-
o <
-5
UJ >
<
« p oc
Km
UJ Q
U UJ
O w
cc =>
QL
O
£
UJ
UJ
B-16
-------
B-17
a *•
c c
- T3 18
«- C L.
a L to
9 3 I
•coo
O '- 3
f o a
wi i tr
z
3-
>
< -
n L
t- o
T3 »-
*• M
1 (fl L
fl i. a
3 O 9)
in o x
L
n a a
• c
•*- JC —
ALE
4- O O
VI » U
IX
a-
CO
4-»
.0
.C
X
c
o
a i-
9 «
•
0 I
L ID Kl
• - C
*. 6 O
U "
a «• *•
3 u «
0-33
•o T: -
• c a
• o >
I o «
<-
ffl
UJ-
o
+*
ID
9
+^
re
**
1/1
r
*•»
*r
I
Id
9
9
E
C
o
a
9
oe
c
0
•o
a
in
a
O
«
9
v
*<
rt-
L
O
u
a
«
M
3
U
in
^-
•o
9
U
C
a
•o
3
a
_
IB
C
O
*rf
(0
z
^
a
3
15
>
w-
TJ
c
*•
U)
a
0
w-
9
>
9
•o
C
o
a
9
a
a
c
v
a
9
£1
T3
C
(0
9
U
C
a
•o
^>
3
a
9
**
a
*»
in
E
«
i.
a
o
u
a
i
u
o
X
SI
c
^
«s
a
^
*^
o
a
9
C
•
H
**
3
a
*<
3
a
u
UJ-
a
o-
z
o
3 a
U) U
M c
— a
•o
10 —
V. 3
« O
a
-------
B-18
Exhibit 4
OTHER TOXICS MANAGEMENT ACTIVITIES
PROGRAMS
1. Great Lakes Toxic
Strategy
ORGANIZATIONS
INVOLVED
- Planning and
Standards Section
- Permits Section
- Pre-Treatment
Workgroup
- Compliance Moni-
toring/Enforcement
Section
CURRENT ACTIVITIES
• Updating the "Pollu-
tants of Concern" list
by Great Lakes National
Program Office.
• Revising WQS for areas
in Lake Michigan.
• Implementing "free from"
language in States'
standards and permits.
• Working with ESD/GLNPO
. on modeling for Lake
Michigan.
• Including "Pollutants
of Concern" in effluent
1imits.
• Evaluating the ongoing
biomonitoring program
for possible modifica-
tions.
-1-
-------
B-19
PROGRAMS
ORGANIZATIONS
INVOLVED
CURRENT ACTIVITIES
• Targeting ESO's
screening surveys to
"Pollutants of Concern"
t Initiating timely
enforcement actions.
2. B i onion i tor ing Policy
Development
- Planning and
Standards Section
- Permits Section
- Compliance Moni-
toring/Enforcement
Section
• Reviewing biomonitoring
programs for WQS impli-
cations.
t Ensuring specific toxics
are being included in
WQS.
• Evaluating effluent
toxicity.
• Monitoring ESD's bio-
monitoring efforts, par-
ticularly tissue con-
tamination monitoring.
• Supporting development
of biomonitoring capa-
bilities at State and
Regional levels, and
broadening its appli-
cability.
-2-
-------
B-20
PROGRAMS
ORGANIZATIONS
INVOLVED
3. Municipal Toxicant
Strategy
- Planning and
Standards Section
- Permits Section
- Pre-Treatment
Workgroup
- Compliance Moni-
toring/Enforcement
Section
CURRENT ACTIVITIES
• Taking appropriate en-
forcement actions as
indicated by results
of biomonitoring.
• Working with ESD to
develop a monitoring
strategy that supports
program objectives.
• Reviewing permits for
anti-degradation issues
• Implementing anti-
degradation components
of the law.
• Identifying toxic dis-
chargers and developing
data via toxicity
testing and biomoni-
toring surveys.
• Defining necessary pre-
treatment programs, and
auditing the ongoing
programs.
t Conducting compliance
inspections/audits to
identify toxic dis-
chargers.
-3-
-------
B-21
PROGRAMS
ORGANIZATIONS
INVOLVED
CURRENT ACTIVITIES
• Establishing Combined
Sewer Overflow controls
as needed.
4. Grand Calumet
River Master Plan
- Planning and
Standards Section
- Permits Section
- Pre-Treatment
Workgroup
- Compliance Moni-
toring/Enforcement
Section
• Developing WQS for Lake
Michigan with an empha-
sis on toxics.
• Implementing/monitoring
sediment studies.
• Working on the "Combined
Disposal Facility"
issue.
• Analyzing the impacts of
dischargers on the Great
Lakes.
• Implementing Waste Load
Allocations (WLA) for
toxics.
• Completing biomonitoring
in canal.
• Including CSO limits in
permits.
-4-
-------
B-22
PROGRAMS
ORGANIZATIONS
INVOLVED
5. Anti-degradation
Policy Development
- Planning and
Standards Section
- Permits Section
- Pre-Treatment
Workgroup
- Compliance Moni-
toring/Enforcement
Section
CURRENT ACTIVITIES
• Incorporating approved
pretreatment programs
into permits and
overseeing local
implementation.
• Taking enforcement
actions that are neces-
sary to bring POTW's
into compliance.
• Ensuring monitoring is
conducted at all
effluent dischargers.
• Implementing consent
decrees.
• Ensuring that all States
have anti-degradation
language in their WQS.
• Reviewing permits to
identify anti-degrada-
tion issues.
• Reviewing models/calcu-
lations.
• Ensuring that States
establish procedures to
implement this policy.
-5-
-------
B-23
PROGRAMS
ORGANIZATIONS
INVOLVED
CURRENT ACTIVITIES
• Implementing policy by
monitoring permits, and
by approving programs
for industrial users,
tributaries and out-
falls.
t Taking necessary en-
forcement actions.
6. Combined Sever
Overflow Strategy
- Planning and
Standards Section
- Permits Section
- Pre-Treatment
Workgroup
- Compliance Moni-
toring/Enforcement
Section
• Assessing WQ for impacts
due to Combined Sewer
Overflow.
• Ensuring that the
Region's guidance to
States re 305(b) Reports
contains a paragraph on
CSO.
• Participating in select-
ing dischargers for CSO
monitoring.
• Ensuring that permits
contain appropriate
CSO language.
• Applying additional pre-
treatment controls to
industrial user contri-
butors.
-6-
-------
PROGRAMS
ORGANIZATIONS
INVOLVED
B-24
CURRENT ACTIVITIES
• Establishing "CSO dis-
charger" priority list,
using policy criteria.
7. POTV Pre-Treatment
Policy Development
Permits Section
Pre-Treatment
Workgroup
Compliance Moni-
toring/Enforcement
Section
• Modifying permits, as
necessary.
• Identifying indirect
dischargers
• Reviewing submitted
programs.
• Obtaining reports on
implementation.
• Providing technical
assistance.
• Implementing removal
credits and "local
limits".
• Reviewing industrial
user variances as part
of oversight
-7-
-------
B-25
PROGRAMS
ORGANIZATIONS
INVOLVED
CURRENT ACTIVITIES
8. Total Residual
Chlorine Strategy
Development
Planning and
Standards Section
Permits Section
Compliance Moni-
toring/Enforcement
Section
0 Reviewing industrial
user variances as part
of conducting overview
of State delegations.
• Tracking implementation
of pre-treatment
schedules. Enforce
via:
- admin, orders
- judicial referrals
• Implementing Enforce-
ment Management System
(EMS).
• Confirming criteria for
TRC.
• Establishing a general
state process.
0 Developing water-
qua! ity based 1imits.
0 Overseeing issuance of
permits which are con-
sistent with approved
State procedures.
0 Tracking compliance
with TRC schedules.
-8-
-------
B-26
APPENDIX A
-------
B-27
LIST OF INTERVIEWEES
Gary Amendola
Max Anderson
Linda Anderson-Carnahan
Barry DeGraff
Charlene Denys
Irvin Dzikowski
Doug Ehorn
Charles Elly
Yvonne Flynn
Jim Giattini
Noel Kohl
Maxine Long
Michael VI. MacMullen
Mark Maloney
Almo Man z ardo
John McGuire
Dave Rankin
Donald Schregardus
Ed Matters
Chief, Eastern District Office, Unit #1
General Biologist, Water Monitoring Team,
ESD
Permits Section
Assistant to the Branch Chief,
Hater Quality Branch
MN/WI/WQS/WLA Specialist
Chief, Permits Section, Unit Jl
Chief, Planning and Standards Section
Chief, Contract Project Management Section,
ESD
Chief, Organic Laboratory Section, ESD
Environmental Scientist, Permits Section
Chief, Planning and Standards Section,
Monitoring and Standards Unit
Microbiologist, Quality Assurance Office,
ESD
WQS/WLA Coordinator
Eastern District Office
Chief, Permits Section
Environmental Service Division,
Environmental Engineer
Environmental Scientist, Permits Section,
Unit H2
Chief, Compliance Section
Chief, Planning and Standards Section,
Planning and Standards Unit
-------
APPENDIX C
DOCUMENTATION OF PROCESS - MICHIGAN
-------
C-l
Section I
OVERVIEW OF MICHIGAN'S WATER POLLUTION CONTROL PROGRAM
A. Introduction
The Michigan NPDES Permitting Program is administered by the Michigan
Department of Natural Resources, Surface Water Quality Division, under the
authority of the Michigan Water Resources Commission Act. This Act strictly
outlaws the discharge of any pollutants into the waters of Michigan which may
be injurious to the public health, aquatic life, wildlife, and utility of
agricultural, recreational or other water uses. The Act authorizes the
Michigan Water Resources Commission to establish water quality standards and
to issue water discharge permits to regulate the discharge of pollutants to
surface waters. The State has been delegated NPDES authority to issue
discharge permits.
Water quality-based toxics limits are an ongoing component of the
Michigan permitting process, and are integrated throughout the State NPDES
program. Michigan has developed a systematic policy for routinely analyzing
wastewater discharges for both toxic, and conventional pollutants. The
Surface Water Quality Division (SWQD), a division of the Michigan Department
of Natural Resources (MDNR) has responsibility for permit development and
overall water pollution control. The Chief of the MDNR/SWQD also serves as
the Executive Secretary to the Water Resources Commission. The Commission
utilizes MDNR staff to assist in approving discharge permits, adopting
regulations and standards, and performing other statutory requirements. The
Assistant Attorney for Environmental Protection within the Michigan Attorney
General's office provides legal counsel and staff assistance to the
Commission.
-------
C-2
The MDNR/SWQD is mandated to administer the following water pollution
control program functions:
• Developing water quality standards which specify the
allowable concentrations of pollutants in surface waters;
t Developing proposed NPDES permit limits, based either on
water quality derived limits or on EPA effluent regulations,
depending on which is more restrictive;
• Monitoring programs to assess water quality;
• Assessing permit compliance and initiating enforcement
actions;
• Administering the federal construction grants program for
municipal wastewater treatment plants;
t Reviewing and approving local government programs to control
industrial dischargers into municipal sewers; and
• Implementing Michigan's commitments to protect Great Lakes
water quality.
B. Purpose
This report documents Michigan's process for developing water quality
standards and proposed NPDES permit limits for toxic pollutants. Water
quality-based (WQB) toxics limits are considered for every NPDES permit issued
in Michigan. Because general narrative water quality standards do not provide
adequate direction, Michigan has promulgated the "Rule 57" process, a blend of
narrative rule and procedural guidelines to calculate parameter-specific
criteria for toxic materials. Michigan believes this approach provides
stringent protection of aquatic life, wildlife, and public health from the
effects of toxic substances. The guidelines contain procedures for
calculating levels in surface water after mix to provide an acceptable degree
of protection to public health from non-threshold cancer effects, and to
aquatic life, wildlife and public health from threshold effects. All WQB
permit limits are calculated from these allowable levels, based on
site-specific discharge and stream flow data.
MDNR/SWQD staff believe that whole effluent toxicity testing/controls can
be useful in certain situations, and that a blend of the chemical specific and
-------
C-3
whole effluent approaches will provide the best regulatory aproach. They
believe that with the current state-of-the-art, whole effluent testing is most
appropriate for measuring toxicity effects on aquatic life. The implications
of whole effluent tests for public health concerning surface water regulatory
programs are currently poorly understood and defined. MDNR/SWQD staff remain
committed to developing whole effluent control techniques, but will remain
cautious in their implementation until the implications of the whole effluent
approaches are better understood.
This report also provides an overview of the MDNR/SWQD organizational
structure, followed by a discussion of the Michigan NPDES Permitting Program
strategy. A more detailed documentation of the Michigan standards-to-permits
toxics process is contained in Section II.
C. Surface Water Quality Division
The Surface Water Quality Division is formally organized into the
following sections:
Permits Section: Primary Division responsibility for
coordinating and implementing the NPDES Permitting Program;
Program Planning and Special Programs Section |PPSPS)|
Division responsibility for data management and water quality
studies for dissolved oxygen; development of conventional
pollutant permit parameters.
Great Lakes and Environmental Assessment Section (GLEAS):
Ambient monitoring for metals, organic chemicals, and
nutrients; bioassays; biological ambient monitoring;
development of permit limitations and requirements for
nutrients, metals and organic chemicals; development of
Remedial Action Plans for Great Lakes Areas of concern;
Mammalian and Aquatic Toxicology; Critical Materials Register
(Surface Water Chemical inventory); CESARS data base
(computerized system on characteristics of chemicals); Great
Lakes monitoring.
Compliance Section: The state is divided into two geographic
areas: T)western and northern lower-peninsula and
upper-peninsula, and 2) southeastern, and served by nine
affiliated district offices. Responsibilities include
compliance monitoring and inspection activities, coordination
-------
C-4
of state-wide pre-treatment policy and municipal control
strategies, and oversight of nonpoint source programs.
MDNR/SWQD manages several individual water pollution control programs.
Each of the programs must meet certain objectives by managing the activities
and resources of the program, and by tracking program performance. Each
program requires support from the five sections, and controls a portion of the
overall staff. The individual water pollution programs are:
Water Quality Standards and Wasteload Allocation. The
objective of this program is to review and revise water
quality standards, and to develop wasteload allocations for
conventional and non-conventional parameters.
Planning. This program's objective is to ensure that state
water pollution control programs address the most significant
water quality and public health problems. This includes
identifying priority waterbodies to guide assessment and
implementation of control methods for sources of pollution.
Environmental Monitoring. This program is charged with
providing valid water quality data to be used in program
evaluation and decision making processes.
NPDES Permit/Pretreatment. The NPDES Permit Program develops
permits with requirements to assure that water quality
standards are not including controls on toxicants and other
important pollutant discharges.
NPDES Permi t/Pretreatment Compliance. The goal of this
program is to improve municipal and industrial compliance
with NPDES permit requirements by identifying existing
compliance problems, and assuring the adequacy of available
enforcement mechanisms.
Grants management. This program is responsible for the
development of priority objectives and performance measures
to ensure compatibility with 106 and 205(j) grant programs,
and to satisfy federal regulations of the Clean Water Act.
State and EPA officials meet and negotiate a set of priority
program and management objectives for each fiscal year.
Nonpoint Source. This program focuses on directing resources
to abate nonpoint pollution on priority waterbodies, and
identifying nonpoint source problems and their impacts on
designated uses.
Great Lakes. The Great Lakes program ensures that
commitments to the Great Lakes Water Quality Agreement are
met. Michigan participates with other States in developing
strategies for remedial alternative actions, and provides
-------
C-5
guidance and technical assistance for the implementation of
programs to abate pollutant-effected surface waters.
Spill response. Michigan maintains an Emergency Response
Program to mitigate the effect of oil spills and other
polluting substances that are not adequately attended to by
industry.
State initiatives: 305(b) Report. This initiative will
provide valid water quality data to be presented in a report
(FY88) to satisfy Section 305(b) of the Clean Water Act. The
report will detail the status of Michigan's water quality and
pollution control activities.
D. Michigan's NPDES Permitting Program
The principal regulatory tool available to MDNR/SWQD to control surface
water discharges of pollutants is the NPDES Permitting Program. All Michigan
surface water dischargers are required by law to have a NPDES permit. NPDES
permits may be issued for a maximum of five years.
Michigan's permitting program is designed to ensure that all 1400
presently permitted dischargers, and new dischargers, have current NPDES
permits. MDNR/SWQD has established a framework strategy for preparing annual
program plans which simplifies decisions on what permitting work needs to be
done for the fiscal year, while maintaining budgetary stability. The strategy
divides the universe of permits into annual priorities for reissuance, and
estimates the average monthly permit issuance workload based on a 5-year
repeating cycle of waterbodies. Because the NPDES Permitting Program is the
primary regulatory tool available to the Division, many of the Division's
other programs are coordinated and scheduled to support the NPDES Permitting
Program. MDNR/SWQD has instituted the following management strategy elements
to direct the Division's resources to successfully meet its target for issuing
discharge permits each year:
• Inventory of Surface Waters -- In order to produce an
inventory of Michigan surface waters, all lakes, rivers,
streams, creeks and drains are grouped by basin. A basin is
defined as a surface waterbody and the land area which is
tributary to the waterbody. Michigan's surface waters are
grouped into 67 basins that form an inventory of surface
water resources requiring water pollution control.
-------
C-6
Inventory of Surface Water Dischargers — Approximately 1400
NPDES facilities discharge into Michigan surface waters. The
Division's programs are responsible for regulating and
controlling all 1400 dischargers, and have grouped all
facilities by the 67 basins. To facilitate its regulatory
mandate, the Division's strategy for implementing surface
water pollution control has been structured on a
basin-by-basin approach.
Michigan Priority Waterbodies — Michigan has developed a
Basin/Discharge Inventory which groups the state's 67 basins,
1400 NPDES dischargers, nonpoint source problem areas, and
Great Lakes Areas of Concern into a 5-year basin plan permit
issuance schedule. The 67 basins are processed across the
State over a 5-year cycle. Clustering of permits will allow
facilities which are allocated portions of the assimiliative
capacity of the same receiving water segments to be
considered at one time. Therefore, the NPDES Permit
Program's FY87 priorities are all waters in the FY87 basins
across the State. The Monitoring Program's FY87 priorities
include all the waters in the FY88 and FY89 basins which will
require permitting actions. The Monitoring Program schedules
activities to support the NPDES Program, and requires 1-2
years lead time (Exhibit 1). Each program's priorities will
depend on how that program's work supports the NPDES permit
5-year basin plan schedule. The monitoring program also
responds to water body concerns outside the permitting
schedule depending on their priority and available resources.
Permit Issuance Schedule — Sets forth a plan and timetable
for reissuance of all permits, both major and minor, based on
receiving priority waterbodies. The State initiated a plan
to synchronize permit expirations (and new issuances) with
the 5-year basin plan. Upon completion of the implementation
plan, a complete cycle of reissuances will occur every 5
years, with approximately 20% of the permits being reissued
each year. The permit issuance schedule will be known far
enough in advance to allow timely and systematic intensive
basin studies to ensure current data is available for setting
new permit limits. The plan provides for priority permits to
be issued (including new permits), plus modifications and
reissuances which cannot wait until the regular reissuance
for the receiving waterbody. This strategy is necessary to
improve management of the program by coordinating permit
processing, water quality studies, development of Total
Maximum Daily Loads (TMDL) and Waste Load Allocations (WLA)
for receiving water bodies, and incorporation of changes in
Water Quality Standards (WQS) and Federal Effluent Limit
Guidelines into permits. The long-term goals of the strategy
are to issue high quality permits, eliminate the backlogs of
expired permits, and to continue reissuing in a timely manner
so that backlogs of expired permits do not redevelop.
-------
I-/
Resources are not presently available to completely carry out all the
elements of this strategy. However, MDNR/SQWD management believes this
process is the most efficient way to perform the NPDES Permitting Program
mandate. New permits and major permit reissuances are of the highest priority
and will be processed with current staff levels. MDNR/SQWD will pursue
increases in funding/staff and improvements in permit processing efficiency to
meet all the objectives of this strategy.
-------
= =
!/) U fl O
& jj oj -.-
— , *J u 1/1
ID S.
E >> <*> t
l_ CO QJ O
QJ a: <->
CO
o
Compliance Monitoring
And Enforcement
Activities
tJ
O
1
(
UJ O
">
Review
t,^
ting
ce Evaluation Of
ite Field Work
1 — 1
-f- 1/1
*^ 1
**- C
0 0
eg
§1
E2
O
CT>
<= —
^
tn c
i <£
Study
ft Pr.orlty
C CT
C C
^.' t^.
•
— i_ -o
e. c
c. -= —
< c u
i — G.
o. s- w
W C. «
C. C. 3
oc
-------
C-9
Section II
MICHIGAN STANDARDS-TO-PERMITS TOXICS PROCESS
The Michigan NPDES Permitting Program standards-to-permits toxics process
is presented below. The detailed process is documented ( a graphic overview
is provided in Exhibit 2) from the initial pre-application priority waterbody
field studies to permit issuance by the Michigan Water Resources Commission.
A. Priority Waterbody Studies
The process for reissuing a NPDES permit begins about one year before a
permit application is officially received by the Surface Water Quality
Division (SWQD), Michigan Department of Natural Resources (MDNR). The
Division prioritizes scheduled water body studies based on the degree of
anticipated activity for issuing permit renewals and requests. The Great
Lakes and Environmental Assessment Section (GLEAS), and the Program Planning
and Special Programs Section (PPSPS) are responsible for monitoring and
conducting any necessary field studies to evaluate surface water quality. The
on-site field study will also address new pollutant concerns that were
previously unknown during the issuance of the expired permit. The data is
processed and forwarded to the Permits Section to be evaluated in the permit
application review.
Participating SWQD units: GLEAS
PPSPS
B. Application Review
The application review process consists of a series of administrative
functions which focus on gathering the necessary information from the
permittee, EPA and SWQD required for issuing/reissuing a permit. The sequence
of events is:
• Applications are sent directly to the Permits Section by the
applicants and are logged in. The appropriate Unit
Supervisor will determine if the application is scheduled to
-------
C-10
be processed during the fiscal year in accordance with the
5-year plan and current program plan priorities.
0 If the application is to be processed, the Unit Supervisor
will review it for administrative completeness.
Concurrently, a copy of the application is sent to the
appropriate SWQD District Office for review. The District
Office has 20 days to forward comments on the completeness
and accuracy of the information in the application and to
provide any additional comments on site acceptability,
recommended special conditions for the permit or compliance
problems that could delay permit action. District comments
should be put in writing; however, informal discussions that
might expedite the process are encouraged.
• Within 30 days of receipt of the application, the Permits
Section will notify the applicant of the application status.
The letter will state one of the following:
i. The application is acknowledged as administratively
complete and the applicant is informed that it has
been assigned to the appropriate permit unit for
processing. The applicant is also informed that
during the processing of the permit additional
information may be requested if it is deemed
necessary to complete or correct deficiencies in
the application.
ii. The application is determined to be incomplete; the
applicant is informed of the deficiencies and is
requested to provide the necessary information by a
certain date.
iii. If the application cannot be immediately processed
due to current program plan priorities, a cursory
review is completed to determine if sufficient
information is provided to consider the application
for renewal. If sufficient information is
available, a "delayed processing" letter is sent to
the applicant informing him when the permit is
expected to be processed. A copy of the letter,
along with the application is also sent to the
District Office.
Participating SQWD units; GLEAS
Permits Section
District Office
Environmental Enforcement Division
Water Quality Studies Unit
Water Quality Appraisal Unit
-------
C-ll
C. Permlt Drafting
The permit drafting phase of the process initiates the implementation of
Rule 57 — a narrative water quality standard which provides specific
authority and guidelines for implementing water quality standards for toxic
substances. Rule 57 contains: a process for developing site-specific
numerical water quality criteria applicable to point source discharges, a
definition of the universe of pollutants to which the rule applies, a
statement setting a 1 in 100,000 cancer risk level, a statement that levels
apply at the edge of the mixing zone, and a mechanism and conditions for
variances from the numerical criteria. In addition to Rule 57 requirements,
Michigan's toxics control process also includes a rule for mixing zones (Rule
82) and a rule for seasonal wasteload allocations (Rule 90). The Rule 57
concept of blending a narrative rule with specific guidelines provides a more
flexible package for implementing toxic permit limits than if all the details
of the guidelines were in rule form. The sequence of events in this stage of
the process is:
• The Water Quality Studies Unit (conventional parameters) and
the Water Quality Appraisal Unit (toxic parameters)
coordinate resources for developing water quality based
limits for the permit. Once the permit application has been
acknowledged as administratively complete, the respective
Unit Supervisor will review the application to determine if
treatment technology-based effluent limits (TTBELs) and/or
water quality based-effluent limits (WQBELs) are needed. The
Unit Supervisors will assign the application to their
respective statewide specialists or other staff members for
development of TTBELs. The appropriate technology-based
recommendations will be provided by memo within 30 days to
the respective Unit Supervisor.
• Concurrent with the development of the TTBELs, the respective
Unit Supervisors will screen the application in accordance
with the approved screening criteria to determine if the
application should be evaluated for WQBELs. The screening
criteria will identify those groups of discharges that do not
need formal WQBEL development because TTBELs will be more
stringent than WQBELs. If it is determined that WQBELs are
needed, the Unit Supervisor forwards a copy of the
application, along with a WQBEL request memo indicating the
request type and the priority to the Planning and Special
Programs Section-Water Quality Studies Unit. The WQBELs are
due 30 days after receipt of the request memo. An extra 20
days will be necessary if new low flow information is needed.
-------
C-12
The following procedures are instituted by both water quality
units to arrive at conventional, and/or toxic water quality
based limits:
i. Identify the location of the facility's surface water
outfall(s) using topographical maps. These maps
provide logistical information for other point
sources and/or public water intakes in the
upstream/downstream vicinity of the permit
applicant's outfall(s).
ii. Review appropriate water quality standards to
determine the designated uses of the receiving water.
Available physical, chemical and biological data for
the receiving water are also researched.
iii. Identify and quantify chemicals known or expected to
be present in the facility's surface water outfall(s)
to establish a list of chemicals for which water
quality based effluent limits (WQBELs) may be
considered. Information sources should include:
NPDES Permit application, Short-term Wastewater
Characterization Studies (short term monitoring
requirements which substitute for incomplete permit
applications), NPDES Compliance Monitoring data (MORs
monthly operating reports submitted by the
permittee to the District Office which detail the
permittee's monthly discharges), field studies,
Michigan Critical Materials Register (Annual)
Inventory for the facility, U.S. EPA BAT Development
Documents for the applicable industrial category,
U.S. EPA Treatability Manuals for the applicable
industrial category, and MDNR/EPA Wastewater Survey
Reports. If insufficient quantitative data are
available to evaluate the pass through potential of
certain chemicals, short-term or long-term effluent
monitoring may be required.
iv. Determine the designated uses of the receiving water
as established by Rule 1100 of the Michigan Water
Quality Standards. Physical, chemical and biological
data available for the receiving water should also be
researched.
v. Identify those chemicals in the permittee's discharge
which lack sufficient data in the literature to
satisfy the minimum aquatic and mammalian acute
toxicity data requirements set forth in the Rule
57(2) guidelines. Recommend that the permittee be
required to perform the aquatic and/or mammalian
acute toxicity tests needed to satisfy these
requirements.
-------
C-13
vi. Determine if the permittee is an appropriate
candidate for whole effluent biomonitoring. If the
permittee is identified as an appropriate candidate,
a site-specific biomonitoring strategy should be
formulated and implemented.
vii. Identify the Rule 57(2) guideline aquatic and
terrestrial criteria for chemicals in the permittee's
discharge(s).
viii. Select the most restrictive of the following Rule
57(2) guideline-derived values for each chemical in
the permittee's discharge:
Aquatic chronic value (ACV)
Terrestrial life cycle safe concentration (TLSC)
Human life cycle safe concentration (HLSC)
The concentration providing an acceptable degree
of protection to public health for cancer when
sufficient data are available in the scientific
literature to establish that a chemical is a
carcinogen, hereditary mutagenic, or genotoxic
teratogenic.
ix. Calculate, -pursuant to Rules 82 and 90 of the
Michigan Water Standards, the WQBEL necessary to
guarantee that the value selected above for each
chemical discharged on a continuous basis is not
exceeded in the receiving water after mixing.
x. Use mass balance equations, environmental fate and
transport models, and best scientific judgement about
the interactions with other chemicals to establish
theoretical daily maximum and/or monthly average
WQBELs.
xi. Determine whether chemicals are being discharged by
the permittee in sufficient concentrations to
warrrant the inclusion of the theoretical WQBELs.
Decisions concerning the need for a WQBEL
recommendation will be based on the difference
between the average and maximum effluent
concentrations and the theoretical WQBELs.
xii. Calculate total maximum daily load and wasteload
allocation (for multiple point source dischargers)
for chemicals discharged to the surface water by
permittees on a case-by-case basis when adequate
environmental fate data are available.
-------
C-14
xiii. When a non-threshold carcinogen is being discharged
below a level which warrants the inclusion of a WQBEL
in the NPDES permit, determine a site-specific
strategy for regulating the chemical in the NPDES
permit.
xiv. Prepare a draft memo which includes: WQBELs,
monitoring requirements, and the basis for each
toxics-related permit condition recommendation and
forward to the Permits Section.
• The completed WQBELs are forwarded to the appropriate Unit
Supervisor who assigns the facility to one of his staff
members for permit drafting.
• The first draft permit is prepared by the unit staff member
assigned to the facility within 15 days after receipt of the
WQBEL and/or TTBEL recommendations. Permits Section staff
will use their judgment to inform other staff members, as
appropriate, of decisions being made during this time. For
example, if the WQBEL or TTBEL recommendations require the
inclusion of interim effluent limitations or compliance
schedules, the Permits Section will informally review these
first with the District before the draft permit is completed.
• Upon completion of the draft permit, the permit processor
prepares a Basis for Decision Memo for the permit development
file. The memo indicates the reasons for the effluent limits
and/or monitoring requirements being selected for inclusion
into the draft permit, and explains any special conditions
and schedules required of the permit compliance. If a
recommended effluent limit or monitoring requirement is not
included in the permit, the memo should state the reasons why
the recommendation was not used.
• The permit processor sends the first draft permit, along with
the public notice and fact sheet (if a fact sheet is
prepared), to the permittee. The first draft permit, public
notice, fact sheet, and basis for decision memo are sent to
the District Office with any additional sections which
included WQBEL recommendations. EPA receives first draft
permits only for major dischargers. The packet mailed to EPA
should also include a copy of the application, any WQBEL or
TTBEL recommendation memos, and the Basis for Decision Memo.
Comments on the first draft permit are due back to the
Permits Section within 20 days.
t The Permits Section makes any needed changes to the permit
and notice/fact sheet within 10 days.
Participating SWQD units: GLEAS
Permits Section
District Office
Water Quality Studies Unit
-------
C-15
Water Quality Appraisal Unit
Treatment Technolgy Unit
D. Public Notice
Upon the completion of the draft permit, the permit is placed on public
notice for 30 days. In most cases, there is little objection to the permit
specifications because of the care taken during the drafting of the permit to
meet and negotiate the permit limits with the permittee. The specific
sequence of activities during this phase is:
• The draft permit is placed on public notice with a public
comment period of 30 days.
• The draft permit (with public notice and fact sheet) is sent
to the permittee, the District Office, adjacent property
owners listed in the permittee's application, and any names
included on the mailing list for public notice. Monthly
lists of all permits prepared for public notice, and all
permits issued are sent to EPA (these are from the monthly
activity reports). For discharges to interstate waters, the
draft permit and public notice is sent to any other states
whose waters could be affected by the discharge.
t If objections are raised concerning the particulars of the
draft permit, a public meeting or public hearing will be held
to discuss areas of disagreement. Permits Section staff will
attend the meeting to present MDNR/SWQD rationale for the
permit specifications, and written responses will address all
comments made during the public hearing.
Participating SQWD Units: Permits Section
E. Permit Issuance
Once the Permits Section resolves concerns raised during the public
notice period, permit issuance activities are initiated. They include:
t The permit processor prepares the proposed permit and the
Water Resources Commission (WRC) informational packets. The
proposed permit is placed on the WRC agenda for action.
• The WRC takes action on permit issuance.
t The approved permit document is signed by the WRC Executive
Secretary. Copies of the signed original are sent to the
permittee, the District Office and EPA.
-------
C-16
Participating SWQD Units: Permits Section
Water Resources Commission
F. Compliance Monitoring/Enforcement
The MDNR/SWQD Compliance Monitoring/Enforcement Program is divided into
two sections by geographical area: the upper-peninsula and northern and
western portion of the lower-peninsula (Section 1), and southeastern Michigan
(Section 2). Nine District Offices are divided among the two areas and are
responsible for conducting compliance activities and design reviews for all
dischargers in their district. Section 2 is also responsible for developing a
State-wide POTW pre-treatment program and administering the new Nonpoint
Source Program. Section 1 is responsible for coordinating State-wide
municipal control strategies. Current MDNR/SWQD goals are to conduct a major
compliance inspection at every major facility once a year with minor
facilities visited an average of once every three years. MDNR/SQWD
coordinates its inspection schedule with the Regional EPA office to ensure
that all facilities are included in the inspection schedule.
Among the specific programmatic activities related to the permit process
are:
• Annual on-site inspections of the permittee's discharge,
inspecting the plant's outfall and wastewater treatment
processes, and reviewing sampling data are conducted. The
primary types of inspections are:
CSI (Compliance Sampling Inspection): The inspector
samples the final effluent and the effluent in the plant
processes. This process usually takes 16-30 work days.
CSIT (Compliance Sampling Inspection for Toxics): The
inspector will sample the final effluent for priority
pollutants, permit parameters and any other toxic
substances. The resource-intensive inspection may
involve biomom'toring activities in which samples are
taken to run tests for acute, and chronic effluent
toxicity.
• Discharge monitoring reports (DMRs) are generated monthly by
the permittees and are forwarded to the compliance section
for data entry with the federal Permit Compliance System
(PCS). The District Offices review the DMRs to ensure that
-------
C-17
the content of the permittee's outfall is meeting the limits
specified in the permit.
t If the District Office discovers non-compliance activity
either through a planned inspection visit, or a review of
DMRs, a series of informal and formal enforcement actions
escalating in severity can be instituted. The steps in the
escalation process do not have to be followed sequentially.
Based on the severity of the problem, an action may be
started at any step in the process. The informal enforcement
actions include:
An informal phone call or meeting arranged by the
District Office with the permittee identifying the
compliance violation and requesting correction of the
problem within a specified time period.
A letter to the permittee, by the District Office,
identifying the violation and requesting that the
permittee come into compliance by a specific date.
A Verbal Communication Report (VCR). A formal phone
call is made by the District Office informing the
permittee of the compliance violation. A form is filled
out noting that the phone call has been made and that
permittee corrective action is expected by an agreed
upon date.
A Notice Letter is a more firmly written document
detailing the nature of the violation, specifying
corrective actions and setting a date for full
compliance.
If none of the above mechanisms provides sufficient incentive to the
permittee to correct compliance violations, MDNR/SQWD can begin more formal
enforcement actions. These include:
A Notice of Non-Compliance, signed by the District
supervisor, detailing the compliance violation and
history of inaction by the permittee, and strongly
directing the commencement of corrective action.
/i Notice of Violation. This action must be reviewed by
the Environmental Enforcement Division (EED), and be
signed by the Surface Water Quality Division (SWQD)
Chief, EED Chief and the Compliance Section Chief. This
notice is a more formal version of the Notice of
Non-Compliance, with the added threat of legal action by
the State Attorney General's office if corrective action
is not completed under the schedule set forth in the
notice.
-------
C-18
A Director's Order and Stipulation is a consent
agreement between the SWQD and permittee which specifies
what steps the permittee must take to return to
compliance. This order may last for up to a year and
sets a time frame for permittee action before further
enforcement actions will be taken by the SWQD. This
notice must be signed by the compliance section
Director.
A Final Order of Abatement can be issued only with the
consent of the Water Resources Commission, and the
Compliance Section Director. This is a statutory
document that may override the particulars of the permit
being violated and set new interim permit limits.
If all of the above mechanisms fail, the permit can be
revoked, and the matter referred to the EED for action
by the Attorney General's office for litigation.
The Compliance Section will use all of the enforcement actions at
its disposal to take the most appropriate action warranted by a
compliance violation. This process will be similar for toxic and
conventional parameter violations. However, a violation of a
toxicant parameter may, depending on potential aquatic and human
health impacts, necessitate an escalation in the severity of the
enforcement action process.
Participating SWQD Units: Compliance Section
-------
C-1'9
o
en
£
£
u
•
n
(75
e
re
-------
APPENDIX D
TRENDS AND CHANGES
-------
0-1
Exhibit 2
Trends and Changes 1n Region V's
Water Toxics Control Program
t The Region will increase emphasis on improving State bioassay
capabilities for toxics.
• There will be greater emphasis on biological surveys to
assess toxics impacts.
• There will be increased Regional use of computers and
computer modelling; e.g., developing/assessing toxics data
bases and wasteload/TMDl allocation models.
• There will be an increased Regional focus on identifying and
developing controls for complex toxics situations; e.g.,
chemical and/or organic interactions requiring more
sophisticated solution techniques.
• The Region will increase its emphasis on oversight of State
toxic sludge management activities; e.g., identification and
disposal of toxic sludges.
• Greater emphasis will be placed on health risk assessment.
t The Region's management role in pre-treatment programs will
decrease as States assume program responsibilities.
The expected decrease in the number of "Federal Interest
Cities" (from the perspective of the pre-treatment program)
will enable the Region to shift its resources to oversight of
State pre-treatment programs.
• There will be increased emphasis on the technical aspects of
toxics compliance monitoring and on taking enforcement
actions against non-complying toxics dischargers.
t The Region will place greater emphasis on encouraging and
assisting States in improving their inspection and
enforcement capabilities for toxics dischargers.
t Greater demands will be placed on Regional staff to serve as
expert witnesses and to speak at public and evidentiary
hearings.
-------
APPENDIX E
PHASE III/IV SURVEY INSTRUMENT
-------
Region V
WATER MANAGEMENT PROGRAM
SURVEY OF STAFF
KNOWLEDGE, SKILLS AND ABILITIES
American Management Systems, Inc.
1777 North Kent Street
Arlington, Virginia 22209
E-l
-------
E-2
INSTRUCTIONS
This survey is designed to obtain information on your educational
background, previous job experiences, and developmental assignments and
training. It is also designed to record your developmental objectives. The
survey is part of a larger effort to make sure that Region V will be prepared
to accomplish its water toxics control program requirements over the next
several years. In order to gain as complete a picture as possible, we are
including staff members from many different organizations within the Region,
and not just those involved in the permit issuance oversight process. Your
responses will not be used for any personnel action. The information obtained
will only be used for structuring training and development programs, not for
job selection.
The questionnaire has several response forms. Some questions are
structured so that you need only check an item or items appropriate to your
situation; other questions can be answered by writing a number which
corresponds to your response on a space next to the item. In addition, you
are provided an opportunity for open-ended responses. Please write clearly
and briefly. Answer only those questions which are relevant to your
background and work experience.
Please take as much time as you need to complete the questionnaire, and
return the completed questionnaire in the enclosed self-addressed envelope.
Thank you for your cooperation.
-------
£-3
Your Name:
BACKGROUND
1. What organizational unit are you assigned to?
A. WMD
1. Water Qua! ity Branch
2. Ground Water Protection Office
3. Safe Drinking Water Branch
4. Municipal Facilities Branch
B. ESD
1. Eastern District Office
2. Central District Office
3. Central Regional Laboratory
4. Environmental Monitoring Branch
2. What is your current pay grade or level?
A. SES
B. CO
C. 6M ; IF GM, Supervisory Nonsupervisory
D. GS
3. Which of the following functional titles best describes your current
position?
A. Division Director
B. Deputy Division Director
C. Branch Chief
D. Section Chief
E. Pre-treatment Coordinator
F. Standards Coordinator
G. "~ Permit Writer/Reviewer
H. Water Quality Modeler
I. Compliance Monitoring Specialist
0. Compliance Engineer
K. Ambient Monitoring Specialist
L. Water Quality Specialist/Biologist
M. Para-technical Compliance Specialist
Other (Please specify):
N.
-------
E-4
4. How long have you been in this position? (Check one item).
A. Six months or less
B. Between six months and 1 year
C. Between 1 and 2 years
D. Between 2 and 5 years
E. Over 5 years
5. Do you hold a college or university degree?
A. Yes
B. No
6. The following are academic degrees that you may have earned during your
academic training:
1. Associate degree
2. Baccalaureate degree
3. Master's degree
4. Doctorate degree
Please indicate below the field or fields in which you earned degrees by
placing the correct number from the list above on the space next to the
appropriate field. If you have more than one degree in a particular
field, please indicate the highest level degree earned. For example, if
you earned a B.S. in chemical sciences, you would place a "2" in the
space next to item C below.
A. Business administration
B. Biological sciences
C. Chemical sciences
0. Computer and information sciences
E. " " 7 Education
F. Economics
G. Engineering technology
H. Geogology
I. Law
J. Natural resources and environmental sciences
K. Physics and mathematics
L. Public administration
M. Public health
N. Other (please specify:)
-------
E-5
7. We are interested in learning what other kinds of jobs you may have
held. Listed below are 19 occupations.
1. Administrative Specialist
(including clerical)
2. Acquatic Biologist
3. Chemist
4. Chemical Engineer
5. Community PIanner
6. Environmental Engineer
7. Environmental Protection
Specialist
8. Environmental Life
Scientist
9. Environmental Scientist
10. General Biologist
11. Geologist
12. Grants Specialist
13. Life Scientist
14. Microbiologist
15. Physical Scientist
16. Program Analyst
17. Physical Scientist
(student trainee)
18. Chemical Engineer
(student trainee)
19. Other
Starting with your most recent job, please indicate (by number) the
occupation of that job. Please also indicate the number of years you
were in the job.
Occupation of most recent job:
Number of years you were in that job:
Occupation of second most recent job:
Number of years you were in that job:
Occupation of third most recent job:
Number of years you were in that job:
What developmental experiences have you had directly related to the kind
of work you are currently doing?
A,
B.
C.
0.
E.
F.
Temporary assignments or details
Special projects
Rotational assignments
On-the-job training
Classroom or formal training
Professional conferences
Other(s): Please specify
G.
H.
I.
-------
E-6
YOUR CURREHT JOB
9. What is your current occupational series? Check one.
A. Administrative and clerical specialist
B. Aquatic biologist
C. Chemist
D. Chemical engineer
E. Environmental engineer
F. Environmental protection specialist
G. Environmental scientist
H. Environmental life scientist
I. General biologist
J. Geologist
K. Grants specialist
L. Microbiologist
M. Physical scientist
N. Program analyst
0. Physical scientist student trainee
Other: (Please specify)
P.
Q. Don't Know
10. The following is a partial 1 ist of water toxics control management
activities. Please review the list, then select the activities and
tasks that you personally work on. Start with the activity or task
listed below that you spend the most time on. Place a "1" in the space
next to it. Then pick the next task that you spend the most time on.
Place a "2" in the space. Continue this process with numbers 3, 4,
5,... until you have identified all of the toxic activities and tasks
you work on.
A. Review of documents/data to identify potential toxics
problems
B. Conduct/review intensive stream survey and ambient
monitoring data
C. Review/revise State water quality standards
D. Establish/review permitting priorities
E. Develop/review water quality based limits (industrial/POTW)
F. Develop/coordinate pre-treatment programs
G. Conduct/evaluate toxicity tests/sample and analyst effluent
H. Conduct/review sediment analysis
I. Conduct/review bioaccumulation studies
-------
E-7
10. (Continued)
J. Calculate/review wasteload allocations/TMDL and weighted
averages
K. Develop model mixing zone policy
L. Conduct/review fate and transport modeling
M. Conduct/review permits appeals process, including
evidentiary hearings
N. Conduct/review compliance monitoring activities
0. Conduct/review compliance evaluation inspection and
compliance sampling inspection
P. Work with States to update their Water Quality Management
Plans
Q. Negotiate overall monitoring strategies
R. Develop case studies of successful toxic strategies
S. Develop POTW sludge analysis procedures
T. Carry out direct enforcement of CWA requirements
U. Other
V. None of the Above
11. On the average, what percent of your time do you spend working on all of
the water toxic-related activities and tasks that you have selected in
question 10. (Reminder: you can spend between 0-100 percent of your
time on all these activities.)
-------
KNOWLEDGE, SKILLS AND ABILITIES
12. Review the list of knowledge, skills and abilities presented below.
To help you understand what we mean when we refer to knowledge, skills
and abilities, we include here working definitions of the three terms:
Knowledge: Refers to an organized body of information, factual or
procedural, that a technician, specialist, or scientist must have in
order to perform the job functions of the water toxics control program.
Skill: Refers to or represents the proficient manual, verbal or mental
manipulation of data, technqiues or things needed to complete specific
tasks.
Abilities: Is the demonstrated power or natural talent to perform a
task at the present time.
Now go through the list of knowledges, skills and abilities and indicate
the extent to which you have each knowledge, skill and ability. Use the
scale below, and indicate your thinking by entering one of the numbers
on that scale on the space in front of each statement. (Please note:
this information will not affect your job status; it will be used to
provide the basis for training and development you may need or desire.)
Rating:
1. No knowledge, skill, or ability
2. Basic knowledge, skill, or ability
3. Intermediate knowledge, skill, or ability
4. Advanced knowledge, skill, or ability
For example: if, in your judgment, you believe you have advanced
knowledge of chemical, biological and physical science principles (Item
d) place a "4" in the space next to that item.
Go through the list and complete all the items.
A. Knowledges
a. Knowledge of theoretical and practical concepts,
principles and practices of the environmental
engineering field in the areas of wastewater and
industrial treatment processes.
b. Knowledge of EPA and State regulations pertaining to
the evaluation of wastewater/industrial treatment
facilities' design and operation.
c. Knowledge of the full range of industrial, municipal
and related wastewater production processes, treatment
processes and discharges.
-------
E-9
12. (Continued)
Rating:
1. No knowledge, skill, or ability
2. Basic knowledge, skill, or ability
3. Intermediate knowledge, skill, or ability
4. Advanced knowledge, skill, or ability
d. Knowledge of chemical, biological or physical science
principles.
e. Knowledge of the Clean Water Act, as amended, and EPA
program policies necessary to plan, conduct and
coordinate an effective overview of the post-BAT
permitting process.
f. Knowledge of current concepts and practices in organic
chemistry, oncology, toxicology, hydrogeology,
biochemistry, ecology and related environmental
disciplines.
g. Knowledge of basic aquatic or human health effects of
toxics.
h. Knowledge of toxics water modeling techniques.
i. Knowledge of the legal aspects of toxics control
management, e.g., permits issuance, appeals, etc.
j. Other
(please specify)
k. Other
(please specify)
B. Skills
Skill in conducting technical analyses to determine
methods for applying Federal and State water quality
standards for permit applications.
Skill in conducting on-site technical visits and
meetings with plant representatives, corporate officers
and their legal staffs, and elected officials regarding
facility treatment and operations methods.
Skill in evaluating data or inspecting facilities to
determine compliance and identify permit violations.
-------
E-'IO
12. (Continued)
Rating;
1. No knowledge, skill, or ability
2. Basic knowledge, skill, or ability
3. Intermediate knowledge, skill, or ability
4. Advanced knowledge, skill, or ability
d. Skill in conducting laboratory analyses, carrying out
sample preparation and handling procedures, and
analyzing data and preparing reports on results.
e. Skill in managing scientific information and data bases
using state-of-the-art technology.
f. Skill in conducting all technical aspects of the
post-BAT toxics program for issuance and modification
of NPDES industrial and municipal permits, including
development of effluent limitations, implementation
schedules, and monitoring and reporting requirements.
g. Skill in developing/evaluating water quality-based
limitations for post-BAT permits.
h. Skill in developing BAT limits for toxics and
pollutants as defined in the NPDES permit regulations.
i. Skill in identifying the presence of toxics and
pollutants in effluent, developing water quality-based
controls, evaluating treatment technology and
evaluating economic achievabil ity.
j. Skill in application of risk assessment and risk
management procedures and in interpretation of
toxicological, chemical, or epidemiological data
particularly as it refers to potential adverse human
exposure.
k. Skill in applying mathematical models for developing
permit limits based on wasteload allocation (WLA) and
total maximum daily loads (TMDL).
1. Skill in the application of toxicity testing procedures
to determine toxic effects of effluent, including the
review and development of effluent toxicity limits.
m. Skill in negotiation and conflict resolution.
n. Other
(please specify)
Other
(please specify)
-------
E-ll
12. (Continued)
C.
Abilities
Rating;
1.
No knowledge, skill, or ability
2. Basic knowledge, skill, or ability
3. Intermediate knowledge, skill, or abili
4. Advanced knowledge, skill, or ability
a.
b.
c.
g.
h.
i
j
Ability to conduct complex field inspections and
investigations at industrial and municipal wastewater
treatment facilities and regulated industries.
Ability to identify and resolve regulatory and permit
violations and other non-compliance issues and
environmental problems which affect health and safety.
Ability to be involved as a technical authority and
witness during permit issuance and enforcement
activities such as conferences, evidentiary hearings,
court proceedings, etc.
Ability to manage projects/programs including planning,
organizing and coordinating activities and tasks, and
conducting project/program evaluations and reviews.
Ability to establish and maintain liaison with State
agencies, overviewing delegated States or assisting
other States in assuming delegation.
Ability to interpret Agency policy for site-specific
criteria modification:
standards.
related to water quality
Ability to communicate orally and in writing with both
scientific and non-scientific groups.
Ability to manage and evaluate the work of contractors
and provide quality control/quality assurance direction
to problems and projects involving environmental
measurements.
Ability to work with computers to analyze data.
Other
(please specify)
Other
(please "specify1,
-------
13. In your opinion, do you believe you have received the appropriate
training for the work you are doing? Place a mark on the space to
indicate your thinking.
A. To a large extent
B. To some extent
C. To a little extent
D. Not at all
14. The following are possible reasons why you might want additional
training and development:
Reason;
1. More effective performance in current position
2. Overall career (individual) development
3. Mission/program change
4. New technology/state-of-the-art
5. New work assignment
Again we list some toxics-related tasks and activities. Please indicate
the tasks and activities for which you need or desire additional
training. Place the number corresponding to the reason for which you
want the training in the space provided. For example, if you desire
more training or development in establishing permitting priorities
because of program changes, place a "3" next to letter "D Establish/
review permitting priorities."
A. Review of documents/data to identify potential toxics
problems
B. Conduct/review intensive stream survey and anbient
monitoring
C. Review/revise State water quality standards
D. Establish/review permitting priorities
E. Develop/review water quality based limits (industrial/POTW)
F. Develop/coordinate pre-treatment programs
G. Conduct/evaluate toxicity tests/sample and analyze effluent
H. Conduct/review sediment analysis
I. Conduct/review bioaccumulation studies
0. Calculate/review wasteload allocations/TMDL and weighted
averages
K. Develop model mixing zone policy
-------
14. (Continued)
Reason:
1. More effective performance in current position
2. Overall career (individual) development
3. Mission/program change
4. New technology/state-of-the-art
5. New work assignment
L. Conduct/review fate and transport modeling
M. Conduct/review permits appeals process, including
evidentiary hearings
N. Conduct/review compliance monitoring activities
0. Conduct/review compliance evaluation inspection and
compliance sampling inspection
P. Work with States to update their Water Quality Management
Plans
Q. Develop overall monitoring strategies
R. Develop case studies of successful toxic strategies
S. Develop POTW sludge analysis procedures
T. Carry out direct enforcement of CWA requirements.
U. Other
V. None of the Above
15. Briefly describe any long-range career goals that you would like to
accomplish within the next 2-5 years.
-------
16. Have you and your supervisor (and/or Division Director) worked on a
Career Development Plan for you?
Yes No
a. If yes, please describe any water-related training and development
needs identified in that Plan.
b. If no, please list and discuss any training and development needs
you may have. (You need not repeat any training needs previously
indicated in question 14 of this survey.
-------
APPENDIX F
PHASE II MANAGERIAL INTERVIEW GUIDE
-------
WATER QUALITY MANAGEMENT PROGRAM
INTERVIEW GUIDE
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
American Management Systems, Inc.
F-l
-------
F-2
INTRODUCTION
Sound management of human resources dictates the need to estimate and
forecast the number, type, and quality of people needed to meet future agency
requirements. At the May 1985 Integrated Water Quality Management meeting, the
Water Program Managers expressed the concern that the current Federal and State
workforce may not possess, in the appropriate quantity, the necessary
knowledges, skills, and abilities to fully implement the post-BAT (i.e., Best
Available Technology) toxics control management processes.
To address that concern, the Office of Water Regulation and Standards
(OWRS), in cooperation with the Office of Human Resources Management (OHRM) and
Region V's Water Management Division (WMD) and Environmental Services Division
(ESD), is sponsoring a human resource planning project that is designed to:
1. Document Region V's current processes for controlling water toxicity;
2.
3.
Define program
the amount of
process);
activities for the purpose of unit pricing (estimating
staff time required to complete the activities in the
Define Region V's current and future workforce characteristics to fully
implement the post-BAT toxics management processes; and
4. Provide strategies for ensuring that Region V has the proper quality of
staff to execute its future program needs.
The main purpose of this interview is to obtain information about (1) the
unit pricing of post-BAT toxics control activities; (2) the future trends in
the post-BAT toxics control program; and (3) the effects of those trends on the
characteristics of WMD and ESD staff. No confidential information is being
collected in this effort.
We are interviewing approximately 20 Region V managers and staff members
who can provide an informed perspective on the effects of the post-BAT toxics
control processes on future staffing needs. Your participation will contribute
significantly to the success of this project.
The interview guide is divided into the following six major sections:
Section I:
Section II:
Section III:
Section IV:
Section V:
Section VI:
Background
Unit Pricing
Trends and Changes in Region V's Water Toxics Control
Program
Water Quality Management Tasks and Required Knowledges,
Skills, and Abilities
Human Resource Planning Experience
Human Resource Planning Perspectives
-------
F-3
SECTION I
BACKGROUND
-------
F-4
ID Code
I. BACKGROUND
Interviewee Name:
Position/Occupation:
Number of Months in Position:
Telephone:
Interviewer:
1. What organizational unit are you assigned to:
a. Water Management Division (WMD)
(1) Water Quality Branch
(2) Compliance Section
(3) Permits Section
(4) Planning and Standards Section
b. Environmental Services Division (ESD)
(1) Eastern District Office
(2) Central District Office
(3) Central Regional Laboratory
(4) Environmental Monitoring Branch
2. Which best describes your current role or staff position?
a. Division Director
b. Deputy Division Director
c. Branch Chief
d. Section Chief
e. Pre-treatment Coordinator
f. Standards Coordinator
g. Permit Writer/Reviewer
h. Water Quality Modeler
i. Compliance Monitoring Specialist
-------
F-5
j. Compliance Engineer
k. Ambient Monitoring Specialist
1. Para-technical Compliance Specialist
m. Water Quality Specialist/Biologist
Other (please specify):
n.
-------
F-6
SECTION II
UNIT PRICING
-------
F-7
II. UNIT PRICING
The purpose of this section is to estimate the level of effort required to
execute particular aspects of Region V's post-BAT toxics control activities.
In Section III, which follows, we will ask you make similar estimates for the
period three years from now. The estimates you provide will assist managers in
determining the number of individuals required to accomplish these activities,
as well as how those individuals will spend their time.
1. For the purposes of this interview guide, the following activities are
included in each of the three categories:
o Oversight of States toxics control permit activities for single
industrial, publicly-owned treatment works (POTW), and multiple
industrial and POTW dischargers. This includes oversight of and
technical assistance in: related standards and planning activities;
all forms of toxics screening and monitoring; determination of permit
limits; issuance of permits; and compliance monitoring.
o Other toxics-related activities, including all toxics activities not
covered in the previous category. Such activities might include:
overseeing of State toxics functions (e.g., training, technology
transfer, QA/QC); granting 205J and 106 moneys to the States; and
conducting POTW sludge bioassays.
o All else, including all activities relating to conventional pollutants.
2. The following is a partial list of Region V's post-BAT toxics control
positions which require the application of professional, engineering, or
scientific knowledges, skills, and abilities:
a. Pre-treatment Coordinator
b. Standards Coordinator
c. Permit Writer/Reviewer
d. Water Quality Modeler
e. Compliance Monitoring Specialist
f. Compliance Engineer
g. Ambient Monitoring Specialist
h. Para-technical Compliance Specialist
i. Water Quality Specialist/Biologist
What other positions should be added to this list?
j-
k.
-------
* • *
* J^H the chart that follows, please estimate the *
* percentage of the time that each individual in your *
* organization (including yourself) spends on Region *
* V's post-BAT toxics control activities, and enter *
* your estimate in the matrix. Include an estimate *
* only if the amount of time spent by the individual *
* in toxics related activities is 10 percent or *
* greater. Use the position titles listed on page 4 *
* above, including those you added. *
-------
Z
O
X
c
u-i
C
C.
Z
O
Z
UJ
a
z
UJ
a
ir
UJ
2
Z
UJ
o
<
O
a
K
z
o
LJ
o <
HI Z Z
l/> ~. O
_P D i-
UJ 3 I-
_l Z
_J U UJ
_] Z >
< « Z
^ O
IT!
O
a
a
UJ
t- 1/1
< UJ
CC -J •-
UJ UJ t-
r a -
i- i >
o i/i —
U h-
x <
o
cr 1/1
i- z
m o
D —
D t-
z «
a
- 5
_i cr
< uJ
>-. O
a tr
i- < uo
i/> i z
o u o
D l/l ~
Z - t-
^- O <
D
UJ X t-
_1 t- —
O O
z a
UJ
£
Z
O
l/l
o
a
-------
F-10
3. Please estimate the number of major permits containing toxics limits that
were reviewed by you and subsequently issued by the States during the last
fiscal year (FY85). Your response will be used to unit price the oversight
and technical assistance Region V provides to the States when they issue
permits. In making your estimate, please include only those permits for
which the bulk of the work was done in FY85. For example, if a permit was
prepared up to the point of issuance in FY85, but was not actually issued
until early FY86, include that permit in your estimate for FY85.
Single industrial and POTW discharger situations
Multiple industrial and POTW discharger situations
4. Using the same assumptions as in Question 3, please estimate the number of
major permits containing toxics limits that will be reviewed by Region V
and subsequently issued by the States three years from now for:
Single industrial and POTW discharger situations
Multiple industrial discharger and POTW situations
-------
F-ll
SECTION III
TRENDS AND CHANGES IN REGION V'S
WATER TOXICS CONTROL PROGRAM
-------
III. TRENDS AND CHANGES IN REGION V'S WATER TOXICS CONTROL PROGRAM
Listed on the following pages is a set of trends or changes that may
characterize Region V's Water Quality Management Program over the next
three years. We want you to rate each of these trends in two ways: (A) in
terms of the probability of occurrence within the next three years; and (B)
in terms of the extent of its impact on the skill mix that will be required
^n three years to perform Region V's post-BAT toxics control charter.
1. Instructions:
A. Trend Probability: In evaluating the probability of a trend, please
note that we are not concerned with whether the trend should or should not
occur, but simply with the probability that it wi 11 occur within the next
three years.
Rate each trend in terms of probability of occurrence using this scale:
High (4): The probability that this trend will occur is greater than
50 percent.
Moderate (3): The probability that this trend will occur is from 25 to
50 percent.
Somewhat Low (2): The probability that this trend will occur is less
than 25 percent.
Very Low (1): The probability that this trend will occur is nearly
zero.
B. Skill-Mix Effect: It is anticipated that each of the trends will have
some effect on the mix of skills you will need in your organization to
carry out future post-BAT toxics control functions and tasks. Consider
each trend and its potential impact on the skill mix needed to perform
Region V's charter, over the next three years.
Rate each trend in terms of its impact on skill mix using this scale:
To a great extent (4): More than 50 percent of the existing staff
members currently lack the skills required; i.e., this trend's
occurrence would give rise to a critical need for specific skills.
To a moderate extent (3): From 25 to 50 percent of the existing staff
members currently lack the skills required; i.e., this trend's
occurrence would give rise to a significant need for specific skills.
To some extent (2): More than 75 percent of the existing staff members
have the skills required; i.e., this trend's occurrence probably could
be handled by existing staff members who have the specific skills
required.
To no extent (1): This trend's occurrence could definitely be handled
by existing staff, who currently have the specific skills required.
-------
Probability scale:
Skill-mix scale:
F-13
Trends:
Moderate Somewhat Low Very Low
3 2 1
To a Great To a Moderate To Some To No
Extent Extent Extent Extent
4 321
Trend Skill-Mix
Probability Effect
a. The Region will increase emphasis on im-
proving State bio-assay capabilities for
toxics.
b. There will be greater emphasis on biological
surveys to assess toxics impacts.
c. There will be increased Regional use of
computers and computer modeling; e.g.,
developing/assessing toxics data bases and
wasteload/TMDL allocation models.
d. There will be an increased Regional focus
on identifying and developing controls for
complex toxic situations; e.g., chemical
and/or organic interactions requiring more
sophisticated solution techniques.
e. The Region will increase its emphasis on
oversight of State toxic sludge management
activities; e.g., identification and disposal
of toxic sludges.
f. Greater emphasis will be placed on health
risk assessment.
g. The Region's management role in pretreatment
programs will decrease as States assume
program responsibilities.
-------
Trend Skill-Mix
Probability Effect
h. The expected decrease in the number of
"Federal Interest Cities" (from the per-
spective of the pretreatment program)
will enable the Region to shift its
resources to oversight of State pre-
treatment programs.
i. There will be increased emphasis on the
technical aspects of toxics compliance
monitoring and on taking enforcement
actions against non-complying toxic
dischargers.
j. The Region will place greater emphasis on
encouraging and assisting States in
improving their inspection and enforcement
capabilities for toxic dischargers.
k. Greater demands will be placed on Regional
staff to serve as expert witnesses and to
speak at public and evidentiary hearings.
-------
F-15
2. In your judgment, what other trends and changes 1n Region V's water quality
program will influence the skill mix you will need in your organization to
carry out the post-BAT toxics control additional functions and tasks? What
will be the extent of that influence?
List the trends and changes and then enter the numbers from the scales
above that best indicate your thinking.
Trend Ski 11-Mix
Probability Effect
a.
b.
3. Given the future program trends and permit projections discussed in the
last two questions, estimate the extent to which you feel these trends and
projections will affect the staffing allocations three years from now.
* On the matrix which follows, please estimate, for your *
* organizational unit, the estimated number of FTE's *
* which will be required for each position involved in *
* Region V's post-BAT toxics control processes. In *
* addition, estimate how, in three years, one person's *
* time will be allocated (in percentages), to the *
* activities defined above. *
-------
c
z
o
cr
cr
<
ku
>
IS
c
Ci
O"
a
c
u.
cc
«
(j <
UJ Z Z
IA <-> O
_l 0 «
UJ 3 »-
_l Z
_) U UJ
_) Z >
*t *••* z
u
o
UJ
*- i >
t- 0 1/5 —
,-. O i-
> >- o
— X <
1- O
(_> 1-
D
D
U -J
0 < 3
-I >- (-
_i cr o
< >- c.
" 3 rf z
UJ O O
5 z cr —
— — UJ (-
u.' cr 3
u. _i < t-
0 a I ~
UJ t— l^
O -J -
< 3 a
1- £
C
Q.
_j cr
«T UJ
^ C
cc cr
h- <. l/1
uo I z
Q un ~
z _. t-
~ 3
uj 3 v-
_) i- i-"
Z Cl.
V) o<
3
- Z
UJ
K S
u. C
a
O L. U.
UJ C
< cr cr
£ UJ <
*-• tC UJ
H S >
l/l 3
uJ Z ro
Z
o
^-
|_,
W
O
a.
C L
a o
E «•<
^j (C
1C C
0. —
U "D
•ft-* L
1 O
a o
1- U
Q.
—
.
I/I
•£
l_ «-
re T
•D
c
(C
4^ t_
to
N
1
-
a
^
—
^ L
2 fl*
J
4~ gj
«- —-
E >
I- 0)
t cr
Ci
n
4-1
.f-
—
re
^ ^
o v
—
L- 0)
D TJ
W S
T
a 4^
£ C IT
U -^ —
C I- -
(c c re
•*-*-•--
— — u
sea;
E o c.
0 S '-T'
\j
in
a
'i_ L
C 0.
re a
•— ^
— --
c" ^
C UJ
^J
c
CTi •*-
c in
— ..-
L ^
*- c re
C •*•- •*"
0; .r- u
— CO)
j2 o a
6 £ irt
r-
re
u
— 0) *•
cum
17 C ""
0 (0 —
O "- <0
4»l .— .r
\ a o
(0 E 0)
L o a
n u 01
a
CO
*•* ^
-^ 4rf
— « *-
(C "~ ffi
5
01
o
•~
F-16
-------
F-17
The following is a list of occupational series involved in Region V's Water
Quality Management Program. Using the first column, select at least 8 of
these occupations that currently are the most critical in terms of carrying
out the water toxics control functions and tasks. Indicate the most
critical occupation by entering a J_ in the sequence space, the next most
critical by entering a _2_, etc.
Using the same list of occupational series, and the second column, now
select at least 8 occupations that you believe will be the most critical
over the next three years, given the changes and trends that will
characterizetheRegion V management processes for toxics control.
Indicate the most critical occupation by entering a _!_ in the sequence
space, the next most critical by entering a _2_, etc.
Current Predicted
Critical Critical Rating
Occupational Series Rating Over Next 3 Yrs
a. Administrative and clerical specialist
b. Aquatic biologist ZZZZ -I
C. Cherr.ist L~._^_
d. Cne^ical Engineer "~ZT
e. Comrrunity Planner ]_ ~~~
f. Environmental engineer
g. Environmental protection specialist
h. Environmental life scientist
i. Environmental scientist ^_~~_
j. General biologist
k. Geologist
1. Grants specialist
m. Life scientist
n. Kicrobiologist
o. Physical scientist " '" _
p. Program analyst
q. Physical scientist student trainee
r. Chemical engineer
Othe-- (please specify):
s.
-------
F-18
SECTION IV
WATER QUALITY MANAGEMENT TASKS AND
REQUIRED KNOWLEDGES, SKILLS, AND ABILITIES
-------
F-19
IV. WATER QUALITY MANAGEMENT TASKS AND REQUIRED KNOWLEDGES, SKILLS, AND
ABILITIES
1. Occupational Series and Position Analysis Matrix:
The matrix which follows is designed to match Region V's post-BAT toxics
control positions with the occupational series that would best fill the
position three years from now. The matrix displays a column for each of
Region V's post-BAT toxics control positions, and provides a space for you
to include any positions you added in the previous section. The
occupational series names are listed along the left margin.
* By placing an X in the appropriate space in the matrix *
* on the following page, please indicate the occupational *
* series of employees that would best fill these post-BAT *
* toxics control positions three years from now. *
-------
g
1
u.
s
w
z
o
-
M
O
••
J
0
t-
X
o
u
**
u
K
O
-
1
I*
Ml
O
&
L.
£
o
— a
• o
3 -
O 0
• -v
•• u
• *
* a
5"
c •
• «
St
a. u
c.
Is
!*
c a
• c
a
i?
OM
O
*•
"c •*
s:
H
II
•
r Quality
Ur
ii
ti
t
£
B C
rj
4. ">
& 4K
U
C
o
•D •
i. C
t> D
C 1.
• o
*• o
M U
*
C
11
• o
I Q
O.W
•
,
< M
«
> U
b.
• *«
c»
„
1
o
A
u
fT
f
C
t
1
HI
S
L.
&
I
,
ii
I
i. •
> c
c -
III
L • —
> o •
c t a
c
I
i
w
c
—
a
o
o
a
o
o
a
0
<-
c
u
u
«
i.
1
,
X
I
t.
a
o
.
]
L.
C
S
^,
-
•
*
c
•
c
-------
2. Defining tasks/activities that are critical to a staff position:
The matrix on the following page provides a means by which you can link
specific post-BAT toxics control tasks and activities with each of the
post-BAT toxics controls positions.
The matrix lists the specific tasks and activities down the left-hand
margin. Across the top, there is a column heading for each of the post-BAT
toxics controls positions. Once the matrix is completed, you will have
identified the specific tasks and activities that are critical to a staff
position. A task or activity is critical to a position when the effective
accomplishment of that task or activity is essential to the successful
performance of the position's responsibilities.
* *
* Place an X in the space under the staff position only if *
* the task or activity will be critical to the staff *
* position over the next three years. *
-------
TASKS/ACTIVITIES CRITICAL TO STAFF POSITIONS OVER NEXT THUtt vt««i
OOST-1AT TOXICS CONTROL POSITIONS
TROC TASKS/ACTIVtTieS
data to Identify
potential to» ic»
problem*
D . ConduC t / rev 1 mm
tntenalve atrea*
aurvey end ewD*eM
a»n1toring data
•tat* Mater Quality
atendardt
d. t»tabi lah/ravia*
p«r«Mt tng
prlortttat
a. CMvalop/ravtaM
•«t»r OuaMty
D«aa0 UaiU*
(tn«w*trtai/POTW)
f . Dawaiep/coordtnata
pra-«r«ataant
pr««rMM
9 . COAOWC t / awa 1 wa t a
toitcfty ta«t»/
»a*pta and a«a»y*a
h. Conduct Sr*v1*v
»*0la«nt ana>y»U
t . Conduct/ raw *•»
titeftccuawtat ten
atud«*s
j. C»)culata/pavta«
•as ta load
*1lec»ttan«/TMOL
t «tO. avarag**
h. p«waiDp awdai
•t»tng iona
I . Conduct /raw* a*
fata and
«. Conduct /rav^ a"
parattt* app«*<*
pracaa*. including
avld«ntlary
haartn«»
cai«H»nc«
•jonltortng
actlwlttat
a . Conduc t / rav t a«
co^tllanc*
•valuation
inapactfon and
coMpt *anca
»*a«>ltne
tnapactlon
p. work with atataa
ta update
tnatr Matar
Quality MQt Ptana
Q. Napatiata avaraii
•onitortno
atratagtat
r. Davalop ca»a
atudtaa of
atratagta*
». Davalop *OTM
•luO9»
•Aatyala
pr«c*dufat
t. Carry out direct
enforcement of
CWA requirement*
Coordinator
Mavia«ar
Heda I ar
% CompHanca Hon»-
t or ing &pec(el tat
-------
T»S«S/ACTIVlTltS CRITICAL TO STUFF POSITIONS OVtR NtxT TMdlt VIMS
POST-BAT TOXICS CONTROL POSITIONS
»OST-»AT TOXICS CON-
TROL TAUS/ACTIV1TIIS
•. ftavla* documents/
data to Idantlfy
potantlal to»l»
praolaaa
b. Canduct/ravtoH
owvay and aaetant
aianltarlng data
atat* Hater quality
atanearda
o. Eat*bUan/ravf««
parKltttng
prterltlaa
a. Davalop/ravla*
•atar quality
baaad Itnlta
Unault rial /POT")
f. Davalop/coordlnata
pra-traata«nt
praarm
a. Conduct /avaluat*
ta«lctty taata/
aaaola and analyia
a* * Iwant
M. Conduct/ravlav
»a«l«*nt anaiyaU
1. Canouct/ravla.
btoaccu«uiat ion
atudla*
•aataload
al lacadona/THOL
a atd. avarapa*
k. bavalap amMl
•(•tn« iana
pal ley
1. Conduct /r»vl««
fata and
tranaport
aodollng
•. Conduct /r«vla»
p*r«lta appaala
pracaat. Including
avldant lary
naarlnga
n. Conduct /ravta*
coapllanca
•eMtOrtng
actlvttlao
o. Cendwct/ravlOH
ea«pl tanca
avaluat Ian
caapuanca
aaa«lln(
Inapact Ion
p. nark >ltn atataa
la upaata
tltalr Mtar
Duality Hat aiana
«. Htgotlata avarai 1
awnttarlnp
atrataataa
r. Da«alop eaaa
otudlat of
atrataglaa
a. Oavalap *OT«
aludea
analyala
pracaduraa
anfarcavant af
Cau raoulraawnta
v^ — ;
Conol lanco
Englnaar
torlno Spoc
Conpllanco Spac
Spac/tlolas»t
-------
F-24
3. The following are examples of knowledges, skills, and abilities (KSAs) that
are used by Region V's post-BAT toxics processes as quality-ranking
criteria in selecting personnel.
This list of knowledges, skills, and abilities is provided to help you
answer the next question. The three terms are defined as:
o Knowledge: Refers to an organized body of information, factual or
procedural, that a technician, specialist, or scientist must have in order
to perform the job functions of the program.
o Skill: Refers to or represents the proficient manual, verbal, or
mental manipulation of data, techniques, or things needed to complete
specific tasks.
o Ability: Is the demonstrated power or natural talent to perform a
task at the present time.
KNOWLEDGES
1. Knowledge of theoretical and practical concepts, principles, and practices
of the environmental engineering field in the areas of wastewater and
industrial treatment processes.
2. Knowledge of EPA and State regulations pertaining to the evaluation of
wastewater/industrial treatment facilities' design and qperation.
3. Knowledge of the full range of industrial, municipal, and related
wastewater production processes, treatment processes, and discharges.
4. Knowledge of chemical, biological, or physical science principles.
5. Knowledge of the Clean Water Act, as amended, and EPA program policies
necessary to plan, conduct, and coordinate an effective overview of the
post-BAT permitting process.
6. Knowledge of current concepts and practices in organic chemistry, oncology,
toxicology, hydrogeology, biochemistry, ecology, and related environmental
disciplines.
7. Knowledge of basic aquatic or human health effects of toxics.
8. Knowledge of toxics water modeling techniques.
9. Knowledge of the legal aspects of toxics control management; e.g., permits
issuance, appeals.
Other (please specify):
10.
-------
F-25
SKILLS
1. Skill in conducting technical analyses to determine methods for applying
Federal and State water quality standards for permit applications.
2. Skill in conducting on-site technical visits and meetings with plant
representatives, corporate officers and their legal staffs, and elected
officials regarding facility treatment and operations methods.
3. Skill in evaluating data and inspecting facilities to determine compliance
and identify permit violations.
4. Skill in conducting laboratory analyses, carrying out sample preparation
and handling procedures, and analyzing data and preparing reports on
results.
5. Skill in managing scientific information and data bases using state-of-the-
art technology.
6. Skill in conducting all technical aspects of the post-BAT toxics program
for issuance and modification of NPDES industrial and municipal permits,
including development of effluent limitations, implementation schedules,
and monitoring and reporting requirements.
7. Skill in developing/evaluating water quality-based limitations for post-BAT
permits.
8. Skill in developing Best Available Treatment (BAT) limits for toxics and
pollutants as -defined in the NPDES permit regulations.
9. Skill in identifying the presence of toxics and pollutants in effluent,
developing water quality-based controls, evaluating treatment technology,
and evaluating economic achievability.
10. Skill in application of risk assessment and risk management procedures and
in interpretation of toxicological, chemical, and epidemiological data,
particularly as it refers to potential adverse human exposure.
11. Skill in applying mathematical models for developing permit limits based on
wasteload allocation (WLA) and total maximum daily loads (TMDL).
12. Skill in the application of toxicity testing procedures to determine toxic
effects of effluent, including the review and development of effluent
toxicity limits.
13. Skill in negotiation and conflict resolution.
Other (please specify):
14.
-------
ABILITIES
1. Ability to conduct complex field inspections and investigations at
industrial and municipal wastewater treatment facilities and regulated
industries.
2. Ability to identify and resolve regulatory and permit violations and other
non-compliance issues and environmental problems which affect health and
safety.
3. Ability to be involved as a technical authority and witness during permit
issuance and enforcement activities such as conferences, evidentiary
hearings, court proceedings, etc.
4. Ability to manage projects/programs, including planning, organizing, and
coordinating activities and tasks, and conducting project/program
evaluations and reviews.
5. Ability to establish and maintain liaison with State agencies, overviewing
delegated States, or assisting other States in assuming delegation.
6. Ability to interpret Agency policy for site-specific criteria modifications
related to water quality standards.
7. Ability to communicate orally and in writing with both scientific and
non-scientific groups.
8. Ability to manage and evaluate the work of contractors and to provide
quality control/quality assurance direction to problems and projects
involving environmental measurements.
Other (please specifiy):
9.
-------
F-27
For each Region V post-SAT toxics control activity
o1" task listed on the following pages, please select
the combination of knowledges, skills and abilities
(KSAs) that you believe will be needed to effectively
accomplish that task three years from now. Use the
above list of KSAs to stimulate your thinking. Please
add other knowledges, skills and abilities as you
think appropriate. Enter their corresponding numbers
on the lines provided.
-------
F-28
1. Review of documents/data to Identify potential toxics problems
a. Knowledge
b. Skills ~ ~
c. Abilities
2. Conduct/review intensive stream survey and ambient monitoring
a. Knowledge
b. Skills
c. Abilities
3. Review/revise State water quality standards
a. Knowledge
b. Skills
c. Abilities
4. Establish/review permitting priotities
a. Knowledge _
b. Skills _
c. Abilities
5. Develop/review water quality based limits (industrial/POTW)
a. Knowledge
b. Skills
c. Abilities
6. Develop/coordinate pre-treatment programs
a. Knowledge
b. Skills
c. Abilities
7. Conduct/evaluate toxicity tests/sample and analyze effluent
a. Knowledge
b. Skills
c. Abilities
8. Conduct/review sediment analysis
a. Knowledge
b. Skills
c. Abilities
9. Conduct/review bioaccumulation studies
a. Knowledge _
b. Skills _
c. Abilities
-------
F-29
10. Calculate/review wasteload allocations/I.M.D.L. and weighted averages
a. Knowledge
b. Skills
c. Abilities
11. Conduct model mixing zone policy
a. Knowledge
b. Skills
c. Abilities
12. Conduct/review fate and transport modelling
a. Knowledge
b. Skills
c. Abilities
13. Conduct/review permits appeals process, including evidentiary hearings
a. Knowledge
b. Skills
c. Abilities
14. Conduct/review compliance monitoring activities
a. Knowledge _^
b. Skills '
c. Abilities
15. Conduct/review compliance evaluation inspection and compliance
sampling inspection
a. Knowledge
b. Skills
c. Abilities
16. Work with states to update their Water Quality Management Plans
a. Knowledge
b. Skills
c. Abilities
17. Develop overall monitoring strategies for toxics
a. Knowledge
b. Skills
c. Abilities
-------
F-30
18. Develop case studies of successful toxic strategies
a. Knowledge
b. Skills
c. Abilities
19. Develop POTU' sludge analysis procedures
a. Knowledge
b. Skills
c. Abilities
20. Other
a,
b.
c.
21. Other
22. Other
Knowledge
Skills
Abilities
a. Knowledge
b. Skills
c. Abilities
a. Knowledge
b. Skills
c. Abilities
-------
F-31
3. Knowledges/Skills/Abilities (continued)
* For each of the following positions, please list other
* important tasks and activities, along with their
* requisite knowledges, skills, and abilities.
*
*
*
*
*
Position Title: Pre-treatment Coordinator
Task/Activity
Knowledges, Skills, Abilities
Position Title: Standards Coordinator
Task/Activity
Knowledges, Skills, Abilities
Position Title: Permit Writer/Reviewer
Task/Activity
Knowledges, Skills, Abilities
-------
F-32
Position Title: Water Quality Modeler
Task/Activity Knowledges, Skills, Abilities
Position Title: Compliance Monitoring Specialist
Task/Activity Knowledges, Skills, Abilities
Position Title: Compliance Engineer
Task/Activity Knowledges, Skills, Abilities
-------
Position Title: Ambient Monitoring Specialist
Task/Activity Knowledges, Skills, Abilities
Position Title: Para-technical Compliance Specialist
Task/Activity Knowledges, Skills, Abilities
Position Title: Water Quality Specialist/Biologist
Task/Activity Knowledges, Skills, Abilities
-------
Other (please specify):
Position Title:
Task/Activity Knowledges, Skills, Abilities
-------
F-35
SECTION V
HUMAN RESOURCE PLANNING EXPERIENCE
-------
F-36
V. HUMAN RESOURCE PUNNING EXPERIENCE
1. Does your organization unit (i.e., the Water Management Division or the
Environmental Services Division) currently have either a formal or informal
process to determine the numbers and/or types of people needed to carry out
the post-BAT toxics control management?
Formal Informal None
For FTEs only
For type of staff (e.g., required
skills) only
For both FTE and type of staff
2. The HR planning process is defined as the process to determine the numbers
and types of people needed to carry out the post-BAT toxics control
management. If there is a process to carry out the HR planning process for
post-BAT toxics management within your organization unit, please indicate
all the method(s) listed below that apply.
a. Decision of top Regional management
b. Meeting of unit (Division, Branch, and Section) managers
c. Aggregation of targets established by Branch and Section managers
d. Establishment via the EPA workload modeling process
e. Establishment through a needs survey
f. Ad hoc decisions
Other (please specify):
9-
h.
i.
j.
-------
F-37
3. Do you think the current skills mix is appropriate for the full
implementation of Region V's post-BAT toxics control processes?
(1) Yes
(2) __ No
If your answer is no, please explain why you think the current skills mix
is not appropriate:
4. Since the mix of skills required to implement post-BAT toxics control
processes is likely to change, an effective HR planning process is
important to post-BAT toxics management.
In your opinion, is the existing HR planning process adequate?
If you perceive that the current HR planning process could be improved,
please provide some examples of how this might be done.
-------
F-38
SECTION VI
HUMAN RESOURCE NEEDS PERSPECTIVES
-------
F-39
VI. HUMAN RESOURCE NEEDS PERSPECTIVE
1. In your opinion, what job characteristics (e.g., commitment to the
environment) provide the greatest source of job satisfaction to Region V's
water quality management employees?
2. Many EPA organizations are faced with the problem of not being able to
retain some of their most qualified scientists, engineers, and other
specialists. To what extent has your organization (WMD or ESD) experienced
this problem?
(1) Not at all
(2) To a minimal extent; i.e., less than 2% turnover
(3) To some extent; i.e., from 2% to 5% turnover
(4) To a great extent; i.e., more than 5% turnover
3. If you selected either 3 or 4 in Question 2, please list what you think are
the reasons (e.g., boredom, lack of opportunity) Region V scientists,
engineers, or specialists leave the water quality management program.
Please be specific.
4. What approaches do you think could be taken to minimize these sources of
dissatisfaction?
-------
F-40
5. In previous sections of this Interview guide, you have Identified future
needs for knowledges, skills, and abilities (KSAs) which staff must have to
effectively Implement post-BAT toxics control management. Which of the
following strategies do you think would be effective in providing a staff
which possesses those identified KSA needs in the proper mix? Please check
all that apply.
a. Training; e.g., opportunities for training in specific areas, such
as mass spectroscopy, of post-BAT-related fields of knowledge
b. Training needs assessment; e.g., based on the results of this study
and the employee survey to follow
c. Staff development, including the implementation of formal career
paths for advancement
d. Staff rotation, either within or among Sections, Branches, and/or
Divisions
e. Clarification of position responsibilities
f. Specialized recruitment; i.e., recruiting focused on individuals
with KSAs required to fill existing gaps
g. Cooperative agreements with industry, the States, and/or academic
institutions
h. Opportunities for high visibility; e.g., speaking engagements,
expert witness assignments
Other (please specify):
6. Which of these (or other) strategies have you tried that worked well? Why
do you think they worked well? Would you do anything differently if you
tried them again?
-------
F-41
7. What strategies have you tried that didn't work? Why do you think they
failed? What would you do differently 1f you tried them again?
8. What kind of training, either in-house or external, is offered to staff to
prepare them for specific post-BAT toxics control activities? Please be
specific.
9. To what extent do you think this training will prepare staff for Region V's
post-BAT toxics control process over the next three years?
(1) Not at all; i.e., the training currently offered will prepare none
of the staff for the post-BAT toxics control process
(2) Very little; i.e., the training currently offered will prepare less
than 25% of the staff for the post-BAT toxics control process
(3) Adequately; i.e., the training currently offered will prepare 50%
of the staff for the post-BAT toxics control process
(4) Very well; i.e., the training currently offered will prepare 75% or
more of the staff for the post-BAT toxics control process
Your comments:
-------
F-42
10. Which of the following KSAs do you see as areas where there is a critical
need for specialized training? Please check all that apply.
Risk assessment/risk management
Toxicology, especially its effects on aquatic and human health
Testing methods for toxics, including effluent analysis, sediment
analysis, bioaccumulation studies
Identifying potential toxics problems
Application of toxicity tests for developing permit limits
Computer and database management
Other (please specify):
11. Which of the following methods do you think would be most effective to
provide the required specialized (i.e., KSA-related) training? Please
'check all that apply.
On-the-job training
Workshops and seminars (external)
Workshops and seminars (internal; tailored to specifically identified
needs)
College and university courses
Other (please specify):
-------
F-43
12. What other types of staff development activities (e.g., job rotation, staff
details) are currently offered to prepare staff for Region V's post-BAT
toxics control processes?
13. How might contractors' employees be used while the post-BAT toxics control
activities develop over the next three years?
14. Are there other human resource planning/management issues that are of
concern to you?
-------
F-44
Thank you for your participation in this study. Your response, along with the
responses of your colleagues, will help to establish a firm foundation for
systematic human resource planning for Region V's post-BAT toxics control. In
addition, the results of this study will provide feedback for further
refinement of the survey instrument as it is used for othe^ Regions.
-------
APPENDIX G
INDEX TO KNOWLEDGE/ABILITY CODES
-------
6-1
APPENDIX G
INDEX TO KNOWLEDGES/ABILITIES CODES
A. KNOWLEDGES
Kl: Environmental Engineering; Treatment Process
K2: Regulations re: Facility Design/Operation
K3: Wastewater Treatment Processes
K4: Chemical, Biological, Physical Prinicples
K5: Clean Water Act; EPA Policies
K6: Organic Chemical and Other Related Sciences
K7: Toxic Health Effects
K8: Toxic Water Modeling
K9: Legal Issues re: Toxics
K10.il: Other (supplied by respondent)
B. ABILITIES
Al: Conduct Treatment Facility Inspection
A2: Identify/Resolve Regulatory Violations
A3: Serve as Technical Authority
A4: Manage Projects
A5: Maintain Liaison with State Agencies
A6: Interpret Agency Policy
A7: Written/Oral Communication
A8: Evaluate Contractors' Work
A9: Conduct Computerized Data Analysis
A10,ll: Other (supplied by respondent)
------- |