A-5
 
-------

-------
                               EXECUTIVE SUMMARY
     This is the  report of  the Environmental Protection  Agency (EPA)  to the
United States Congress on the development  of  wastewater treatment plant opera-
tor training programs  for  improved  publicly  owned  facilities  compliance re-
quested in  the  May  23,  1984,  report  (98-803)  of the  House Subcommittee  on
Appropriations for HUD and Independent Agencies.

Background

     EPA and the States agree that effective  operator training is an important
factor in a treatment  facility's ability  to  meet its effluent  and  operations
and maintenance requirements. However,  it  is  also clear that lack of effective
enforcement, problems with  facility  design and  construction,  infiltration and
inflow; and  inadequate local financial  management and lack  of local  support to
effective operations and  maintenance  also contribute  significantly to plant
performance and compliance problems.   EPA  and States  need  to implement  coordi-
nated, compliance-oriented programs that ensure  the most appropriate responses
to identified compliance problems.

     With respect to the  operator training component of this approach,  EPA's
long-term strategy has been to build an effective, self-sufficient State train-
ing base. Between  1971 and  1981,  EPA's efforts  focused on training of State
trainers, development  of  curricula  and materials, and  construction of State
training centers. EPA  also established the Instructional  Resources  Center  at
Ohio State  University  to serve  as a repository  for training and instructional
materials and to  operate a  national information clearinghouse  and  retrieval
system. The  Center  recently became  self-supporting.    Since 1982,  using  con-
gressional add-on funds, EPA also has  been providing grants to  States to de-
velop onsite training and technical assistance capability  for solving problems
in small  communities  and  grants to  a  national  organization to identify and
help States  implement  the elements  of effective,  compliance-results-oriented
State and local training programs.   EPA has also developed  computerized diag-
nostic models to help  States identify  operations,  management, and  design and
construction problems to target responses to noncompliance.

     Although nearly all States already have  sane elements of a model training
program in  place and  a few  States are very  close to  achieving effective and
self-sufficient training programs, each State will require  additional  actions
to achieve  the  overall objectives of an  integrated State/local/private sector
training and  technical assistance  program oriented  to achieving  compliance
results.

     Although State and  Federal  compliance,  assistance, and  training  efforts
are increasing, local governments have primary responsibility for operating and
maintaining their facilities in compliance. While most larger facilities are in
compliance, small  communities  continue  to  have significant  compliance  and
performance problems.  Small  communities have  not received  comparable levels  of
compliance attention and have not been able to  obtain  governmental  or  private
sector technical and financial management assistance to solve problems.
                                      -v-

-------
     Several national  training and  other  associations that received  EPA finan-
cial and  institutional  support  provide comprehensive  coordination and  assist-
ance to  State and  local governments.  An  estimated 24 State  operator associa-
tions  sponsor  ongoing  operator  training activities.   The  Water  Pollution  Con-
trol Federation  is promoting  a  national operator association that  will  coordi-
nate information  and encourage  operator training.   In addition,  many State and
local  operations  and maintenance and training programs rely heavily on private-
sector training  and  technical assistance.  There  are  increasing opportunities
for the  private   sector to assist  grantees implementing first  year performance
certification requirements;  to  develop contractual  arrangements  for  contract
construction, operations and  maintenance;  and  to  develop  innovative  ways  to
deliver training  and technical assistance to small communities.

Status of State Grant Projects

     Since 1982 Congress has added $11,953,000 to EPA's budget to support oper-
ator training.  Congress  added $4,103,000   in  1982  and  approximately $2,600,000
each for  fiscal  years  1983, 1984,  and  1985.   As directed by  Congress,  the bulk
of the 1982  and  1983 add-on training  funds have been awarded to  States  to help
850 communities by  providing compliance-oriented on site  training and technical
assistance to  operators  of  small  Federally funded  treatment plants. The  1984
funds were  awarded  to  31  States  late  in the  fiscal year;  these States  will
initiate work  shortly  to conduct diagnostic  evaluations  and  provide technical
assistance to additional operators.  Using these funds, several States are also
developing financial management guidance and assistance programs.

      Although States  will  not   complete  work  until  1985  in most  of  the  842
projects funded  in  1982  and  1983, compliance has  already  been attained at  352
plants, and  effluent and operations and  maintenance  performance has been  im-
proved at  132 additional plants.  In  addition,  State  efforts have  resulted  in
improved local decisionmaker  involvement   in  plant  operations and maintenance
and financial  management;  improved  process control  methods and  laboratory  and
recordkeeping practices;  introduction  of   preventive maintenance programs  and
improved repair  of  equipment;  reduced  energy and  sludge  handling  costs;  im-
proved infiltration/inflow management;  and identification  of operator  certifi-
cation and continuing education needs.

      A major objective and accomplishment  in award  of  FY 1982  and  1983 funds
was to obtain maximum State participation  in this program.  By the  end of 1984,
only one  State,   certain territories,  and  the  District  of  Columbia were  not
participating in  this training effort.   Award of  FY 1984  funds was more selec-
tive. Funds  were awarded to  31 States that had demonstrated  a commitment  to
this effort  as  reflected  in funds expenditures  and  compliance  improvement.
Award of  FY  1985 add-on funds will  also  emphasize support to results-oriented
State programs.

National Survey and Evaluation

     To help  evaluate  State  and  local  training  capability,   to  identify  the
essential elements  and  costs  of an  effective  State  operator-training  program,
and to develop Federal, State,  local,  and private sector action  plans,  EPA has
funded studies by the  National   Environmental Training Association  (NETA),  the
Association of  State  and  Interstate  Water  Pollution  Control  Administrators
(ASIWPCA), and  the  National Demonstration  Water Project  (NDWP).   Representa-
tives of  NETA,  ASIWPCA,  and  the National  Association of  Towns and  Townships
(NATaT) also  have participated  on  a work  group with EPA  in developing  this
report.
                                      -vi-

-------
Characteristics_of.._St_ate Operator Training Programs

     States report total  1984  operator training  budgets of approximately $10.2
million. About 19 percent or $2 million was  from local sources,  38 percent or
$3.8 million from State sources, and 43 percent or $4.3 million from EPA funds.
Annual State training  budgets range  from  $25,000 to over  $900,000,  with most
ranging between $100,000  and $400,000.  Local  funding  is generally from course
tuition, fees  and certification  charges.    Federal funds  are obtained  under
Clean Water Act sections  106, 205(g), and 104(g)(l).

     States average  about four full-time  trainers, but  the vast majority  of
staff are part-time. It appears that  a significant amount of additional train-
ing and technical assistance  is provided by other  State personnel in conjunc-
tion with management of construction grants and compliance programs.

     Operator training  programs are  conducted mainly through State  environ-
mental agencies and  State training  centers.   State training centers are gener-
ally associated  with  junior  colleges or  vocational  education  institutions.
These centers serve  as Statewide  training  resource centers and provide primar-
ily entry-level and upgrade training.  As State training programs have matured,
program objectives and  resources  have expanded to  emphasize continuing educa-
tion and technical  assistance as well as  operator  certification.   Nearly all
States (44) have  mandatory  operator  certification  programs.  The majority  of
operators are  certified  and  receive  continuing  education  training  annually.

Conclusions

Roles and Responsibilities

     As the Agency,  the  States,  and local governments work  toward  improved
publicly owned facilities compliance,  including  coordinated, compliance-orien-
ted, and self-sufficient operator training programs, it is important to articu-
late the basic roles and  responsibilities that Federal, State and local govern-
ments and the private sector will be expected to fulfill.

     Overall responsibility  for  operator  training  and plant  compliance  rests
with local and State governments.   Local governments are expected to see that
their plants comply  with their effluent-discharge  permits,  maintain effective
financial management and  user-charge  systems and  operations  and maintenance
programs, and  obtain training  for  their  operators where needed.   States are
expected to develop,  administer,  and  finance effective  training  programs,  to
help especially small municipalities comply with discharge requirements, and to
take appropriate enforcement actions where  necessary.   The  Federal role is one
of oversight and  assistance where  needed  to  assure that needed  programs are
developed and implemented to improve compliance.
                                     -vi i-

-------
Model State Program

     As requested  by Congress,  EPA has  defined the  essential  elements  of  a
model State operator training program  and is working now with NETA and States
to  identify the  implementation costs  in  each State. The  elements of  a  model
program include: 1) an integrated compliance program that provides coordination
among all  involved  State  agencies and the private sector;  2)  a  training  needs
assessment process;  3)  an action  plan that  meets training needs,  sets prior-
ities, and allocates resources;  4)  a training delivery system that coordinates
training delivered  by government and the private sector and  provides the most
appropriate types  of training,  training  materials,  and technical assistance;
5} a mandatory operator certification program that measures operator competency
in the plant, and provides for annual inservice training and recertification as
appropriate; 6) a management  information system that provides essential inform-
ation for program management  and documents compliance  results of training; 7)
State staff training to ensure that trainers  remain  current in new technologi-
cal developments  and training  approaches and  can  provide effective  outreach
assistance to operators and communities;  8)  a public education program target-
ed to local officials and the general  public to promote improved understanding
of compliance  responsiblities and  support  for  investment  in operations and
maintenance and  operator  training;  and 9) adequate  long  term fiscal  support
from local  and  State sources  to maintain  effective  training  programs  once
Federal funding support is no longer provided.

Action Plans

     EPA has been  working with representatives  of  each level of government,
trainers, and the  private sector,  to  develop proposed Federal,  State, local,
and private sector action plans  to achieve overall compliance goals and objec-
tives.  These detailed  action  plans,   described  later  in  the report, define
needed overall management actions  for  coordinating each aspect of the compli-
ance program and actions keyed specifically to operator training program devel-
opment. States and  local  governments should  evaluate  these recommendations in
light of their current  programs and begin to  implement needed  improvements as
quickly as possible.

     EPA has already  taken a  number of actions.  These include issuance of the
National Municipal Policy and Financial Capability Policy,  revised regulations,
and new financial  and technical information  and  guidance  for State and  local
governments.  The agency also  conducted  a national conference in May at Atlanta,
Georgia bringing together State training  officials and EPA staff  to discuss
development of effective, self-sufficient  operator training  programs and to
share information  on onsite  training  and technical  assistance  programs.  An
Administrator's Task  Force on Incentives for  Improved  Operations and Mainten-
ance was established and  issued  a  report  that has formed the  primary basis for
a number of additional  initiatives that are  currently underway  or  being con-
sidered.  EPA also  is working  with NETA  on a 3-year  project to  help States
develop specific action plans for implementing more effective operator training
programs.

     At the State  level,  support for  additional, compliance-oriented operator
training and technical assistance efforts appears to be increasing. States also
appear to support development  of self-sufficient  operator  training programs as
quickly as possible.  Local governments, especially in  small  communities, need
to begin placing more emphasis  on  and committing more  resources to effective
operations and maintenance of their plants and to operator  training.  The addi-
tional actions identified at each level of government  will,  over time, improve
compliance by all publicly owned wastewater treatment plants.

                                     -viii-

-------
                                REPORT TO CONGRESS
                                       ON
                             TRAINING FOR OPERATORS
                 OF PUBLICLY OWNED WASTFWATER TREATMENT PLANTS
 I.   INTRODUCTION

     A. Purpose

       This  is  the report of the Environmental  Protection Agency (EPA) to  the
 United States  Congress  on  the  development  of  improved  wastewater treatment
 plant operator  training programs to assist publicly  owned facilities compli-
 ance.  The  report was  requested by  the House  Subcommittee  on Appropriations
 for  HUD and  Independent Agencies in Report 98-803 dated May 23, 1984.

     B. Background

        1. Federal, State, and Local Roles

           EPA and the  States agree that effective operator training is impor-
 tant to help ensure  that  local wastewater treatment plants, many of which have
 been constructed  with  Federal funds, meet effluent permit requirements and  are
 operated and maintained  effectively.   Primary  responsibility  for  operator
 training and plant compliance rests with State  and local governments.  States
 are  expected to develop  and administer coordinated  Statewide  compliance pro-
 grams, including  effective  operator  training programs,  to  provide technical
 assistance where  appropriate to  help municipalities comply with requirements,
 and  to take  appropriate enforcement actions.  Local governments are required to
 maintain their plants  in compliance  with effluent-discharge  permits; maintain
 effective financial  management,  user  charge,  and  operations,  maintenance and
 management programs; retain  trained operators;  and obtain training  for their
 operators where needed. The  Federal role is to assure development and implemen-
 tation of  comprehensive and  coordinated State  and local programs  to improve
 overall municipal  wastewater treatment facilities  performance  and  compliance.

        2. Large Plant - Small Plant Compliance

           A top  priority of the EPA is to  assure that  municipal  wastewater
 treatment facilities are  constructed, operated  and maintained to  meet design
 and  effluent discharge  permit requirements.  Since  1972 the Federal  Government
 has  spent almost  $37 billion to help conmunities pay  for construction of pub-
 licly owned  wastewater treatment plants that meet the  effluent  requirements
 of the Federal  Clean Water  Act  (P.L.  92-500).  as  amended.  Although  the  vast
majority of  plants funded since  1972 that treat  more than 1  million  gallons
 of wastewater a day  comply with their permits,  small  plants  tend to have  sig-
 nificant performance and  compliance problems.  Small  plants   represent  about
 90 percent of  the total  number  of  facilities  built  since  1972 though  they
 account for  only  about 10 percent of  total municipal wastewater flow.   While
overall EPA  and  State  municipal compliance  efforts  have increased  substan-
 tially, small plants are  unlikely   to receive  substantial direct  compliance
emphasis due to limited  Fodpral  and  State  resources and  national emphasis  on
 nonccmplying plants with the greatest water quality impacts.


                                                        U.S. EPA Headquarters Library
                                                               Matt code 3201
                                      ~l ~               1200 Pennsylvania Avenue NW
                                                           Washington DC 20460

-------
         3. Operator Training and Small-Plant Compliance

           A key  factor  in  compliance problems  at  small  plants is  that the
operators, although  usually  certified,  often  lack  the  necessary  technical
knowledge and  itechancial  skills  needed to  operate,  maintain  and manage the
treatment plant.   Typically  these plants  are  operated  by  one person  who is
responsible for all  aspects of plant operations and  maintenance and  who also
often has to  combine plant operations  with other municipal duties.   This has
meant insufficient attention to plant operation and  maintenance  and  little or
no time  for needed offsite  classroom instruction or "hands-on"  training at a
wastewater treatment training  facility.  These small plants generally have not
received much  State  attention  or assistance  and  have not been able  to obtain
private  sector help.

         4. Results-Oriented Operator Training

           Effective operator training  and technical  assistance  are  important
elements in the  treatment plant's  ability to  meet  its effluent permit.   Im-
proved plant  performance  and  permit  compliance  are  the  ultimate  gauges  of
training success.   Head counts of  operators trained, upgraded,  or  certified,
important as these factors are,  represent  only intermediate, process measures.
Training programs must be able to deliver personal on-the-job assistance to the
operator at the treatment plant as well as  traditional  classroom and textbook
instruction and must bp oriented to improved plant performance and  compliance.
Training programs must  demonstrate  that training  produces  cost-effective solu-
tions to plant noncompliance to draw needed  financial support from  State and
local governments.

         5. Other Factors Affecting Compliance

           Problems with  facility design,  selection  of treatment technologies,
infiltration and  inflow,  inadequate  financial management by  the  local  govern-
ment, lack of  effective  enforcement to spur corrective action at problem plants,
and lack  of  information by local  officials   on  their responsibilities  also
contribute to poor plant performance and noncompliance.  This report  focuses on
operator training  but  also  interrelates  overall  Federal,  State,  local,  and
private  sector efforts  needed  to frame  integrated approaches to improve per-
formance and compliance at municipal wastewater treatment plants.

     C.  Congressional Add-on Funds

        The fiscal 1985  appropriation of $2.6 million additional  Congressional
add-on funds brought  to  S11.3  million  the total  amount of  operator  training
funds added by Congress  to  EPA appropriations for  fiscal years 1982  through
1985.
                                      -2-

-------
        1. Grants to States

           As directed by Congress,  the bulk of the add-on  training funds are
at work  in  the States  assisting  compliance-oriented  training programs  for
operators of treatment plants with capacities  of less  than 5 million gallons a
day (mgd).   Onsite  training and technical assistance  programs  are  underway in
49 States, reaching approximately 1,000 small  plants with compliance problems.
Most of the  plants  have  capacities  of  less  than 1  million gallons  per day and
serve fewer  than 10,000  people.  Training  and  technical  assistance  is provided
onsite and over-the-shoulder by experienced trainers selected by State training
centers, other  responsible  State agencies,  or a national training association.
Trainers use  EPA-developed  computer-diagnostic programs to  identify a plant's
design, operational, and financial  management  problems  that are causing poor
plant performance and noncompliance and to target needed training and technical
assistance activities.    State  and  EPA  data  show that  the program  is having a
very significant impact  in  bringing  plants into compliance, improving effluent
performance, and improving overall operations and maintenance.

        2. Grants to National Organizations

           The EPA  Office  of  Water has  provided  funds  to several  national
organizations to identify essential  elements and costs  of State operator train-
ing programs, to help States implement  coordinated, compliance-oriented opera-
tor training programs,  and to evaluate State training capability. The national
organizations include the  National   Environmental Training  Association (NETA),
the Association of  State and Interstate Water  Pollution  Control Administrators
(ASIWPCA), the  National  Demonstration Water Project  (NDWP), and the American
Clean Water  Association  (ACWA).  These  organizations  have provided  invaluable
assistance in developing this report and formulating action plans for effective
operator training and improved municipal facilities compliance.

    D. Final Report

       The material in this report   reflects  significant input  by  representa-
tives of  NETA,  ASIWPCA, the  National  Association of  Towns  and  Townships,
selected local officials, and EPA regional offices.  The report provides updated
information on  the  status  of  State operator  training programs; State accom-
plishments to date  using congressional add-on  section  104(g)(l)   funds;  EPA,
State, local,  and   private  sector  roles  and   responsibilities;  the  elements
of a model  State operator  training  program;  and a multiyear plan  for needed
additional actions  by  each  level  of  government and  the  private  sector  for
improved operator training and publicly owned facilities compliance.
                                      -3-

-------
 II.  HISTORY AND STATUS OF  FEDERAL OPERATOR TRAINING PROGRAMS

     A.   Federal Program Summary

          The Federal goal  is to protect the public  investment by developing a
 national  base  of skilled  water pollution control personnel, technical informa-
 tion materials,  and effective  State and local programs  to assure that waste-
 water treatment plants, especially  those built with  Federal  funds, are opera-
 ted, maintained,  and managed to comply  with  their effluent discharge permits.
 The  Federal  operator training  effort has progressed through  various stages.
 From 1967 to 1971,  the focus was on  direct training of operators.   Fran 1971 to
 1977, the program shifted  to greater reliance on  the States  by training State
 trainers  and building State training centers. Fran 1977 through 1981, extensive
 curricula and training materials were developed for State use.  Since 1981, EPA
 has  been  working with  States and national organizations,  primarily using con-
 gressional add-on  funds, to  implement  onsite training and technical assistance
 programs  for small  communities; to define the  elements and costs of effective,
 compliance-oriented State  and  local  operator training  programs;  and to accel-
 erate implementation of more effective,  self-sufficient programs.

          In support of these objectives and activities, EPA's National Munici-
 pal Policy requires compliance  by these  facilities as scon as possible, and not
 later than  July  1,  1988,  except in extraordinary circumstances.   The policy
 requires  that  all  publicly  owned  treatment works  meet  statutory compliance
 requirements whether or  not they receive  Federal funds.   Already constructed
 publicly owned  treatment works  that  are not in compliance must develop a plan
 and schedule for achieving compliance. Municipalities that rpquire construction
must also develop a plan  that  documents treatment  needs, costs,  a financing
approach, and a  schedule for achieving  compliance as  soon as  possible.  Opera-
 tor training has  an integral  role in the plan's  implementation since training
 can improve plant performance and,  through effective operations and maintenance,
minimize  the need for capital investments.


     B.  Federal Program Accomplishments

         Over the past  17 years,  EPA and predecessor agencies  have  invested
approximately $75  million  in   operator training-related  programs,  including
 specific training programs and  other State grants support.  Over 20,000 opera-
tors and  State  trainers have been trained. A wealth of  water  pollution control
curricula and  training  materials have  been developed  and are  being used  by
State agencies, training centers, other  educational  institutions, and training
and water pollution control associations.
                                      -4-

-------
        Of the total Federal funds, $15.6 million went to programs funded under
the 1962 Manpower Development and Training Act (P.L. 87-415) which funded entry
level and upgrade training.  Approximately $27 million went  to programs funded
under section  5  of  the Water  Quality Improvement  Act  of 1970  (P.L.   91-224)
and section  104(g)(l)   of the  1972  Water  Pollution Control  Act  Amendments
(P.L. 92-500) which authorize operator training pilot programs; and S10 million
went to  fund establishment of 27  State  training centers under  section 109(b)
of the 1972  Act  and  1977  Amendments  (P.L.  95-217).  Significant  amounts  of con-
struction grant  funds have been used to  provide  facility startup assistance to
communities and  operators and to  develop operations and maintenance  manuals.
In addition,  the 1981  Amendments (P.L.  97-117)   provide  expanded  statutory
requirements for  communities to   include  operator  training under  first-year
startup assistance.   States  also  have  continued to receive  Clean Water  Act
sections 106 and  205(g) funds for operator training and operations and main-
tenance management activities.   Section  104(g)(l)  congressional add-on  funds
have been  provided  since  1982  to  support  onsite  training  and  technical
assistance to  operators of  small treatment  plants.  Uses of  these funds  are
discussed in detail in a later section of this report.

        The Instructional  Resources  Center (IRC) at  Ohio State University  in
Columbus, Ohio, established under an EPA grant, operates a national information
clearinghouse and serves  as  a repository for training and instructional mater-
ials developed by EPA,  States,  and the private sector.  IRC houses the Instruc-
tional Resources Information System (IRIS), a national computer information and
retrieval system  that   lists  thousands of  available instructional  resources.
IRC also publishes a quarterly newsletter; sponsors conferences, workshops,  and
seminars; and operates  a  lending  library  of audiovisual  materials.   The Center
handles over  4,000   requests each month primarily  from plant  operators  and
supervisors. The  IRC reviews  training  materials  and annually accepts  about
1,000 into  IRIS. The   Center  mails  out  20,000 newsletters  each  month  and
receives approximately  200 requests  for  information daily.   Over 1,500 slides
and 20 videocassettes  are duplicated  for loan each month.   The Center became
self-supporting in 1984.

        More detailed information on the history and development of the Federal
program is  contained in a report  issued  by EPA's  Office of Water  in  1983  en-
titled "Operator Training  Programs"  and  in the Preliminary  Report  to  Congress
on Training  for  Operators of Municipal  Wastewater Treatment Plants  submitted
March 1, 1984.


     C.  Elements of National Training Base

         1. State Training Centers

            Twenty-six States, the District of Columbia, two territories,  and
one interstate agency now operate dedicated training centers; 27 of the centers
were funded under section 109(b) of the Clean Water Act.  The States of  Alabama,
Alaska, Louisiana,  Nebraska, Montana, Hawaii,  Oregon,   and Puerto  Rico  are
considering establishing  109(b) centers.   Attachment A lists existing  training
centers.
                                      -5-

-------
         2. National Associations

            Several national associations  that  received startup or continuing
financial and  institutional  support from EPA continue  to  provide  a comprehen-
sive coordination  and assistance  capability to  State  and local  governments.
These associations  include  the Joint  Training  Coordination  Committee  (JTCC),
the National  Environmental  Training  Association  (NETA),  the  National  Demon-
stration Water  Project  (NDWP), the  American Clean  Water Association  (ACWA),
and the  Association of  Boards of Certification  for Operations  Personnel  in
Water and Wastewater Utilities (ABC).  The Association  of State and Interstate
Water Pollution Control Administrators (ASIWPCA)  provides  an  important  coordi-
nation function across  all  State  water pollution control programs. The  Water
Pollution Control Federation (WPCF)  is also actively involved in education and
private sector  coordination.   The Federation is prcmoting establishment of  a
national operator association  to  coordinate information and encourage  operator
training.  The  Federation publishes  a monthly  magazine  on  plant  operations
written for and directed to plant operators.

         3. Operator Associations

             An estimated 24  State operator  associations  sponsor  some  of  the
strongest and most effective  operator training activities.   Some  work  closely
with State agencies  to  conduct and  coordinate  training courses and Statewide
conferences.  These associations  generally were  established  with  strong  sup-
port frcro the Water Pollution Control Federation.

         4.  Private Sector

             Every State and many local governments rely heavily on the private
sector to provided needed training and technical assistance.   In several cities
private contractors ar<=> responsible for overall facility operations and mainten-
ance and operator  training.   Contractor  involvement in operator  training  is
expected to expand in conjunction with new statutory requirements that  grantees
certify that their facilities  are in compliance  with effluent  requirements  by
the end of the  first year of plant operation. There  are also  increasing  oppor-
tunities for private sector  support in  small conmunities using innovative  on
site approaches and computer technology.
                                      -6-

-------
 III.  STATE ON SITE TRAINING AND TECHNICAL ASSISTANCE ACCOMPLISHMENTS
      A.  Allocation of Section  104(g)(l) Congressional Add-on Funds

          In FY  1982,  Congress  added $4.1 million  to EPA's budget  to assist
State operator  training program  activities  and to  pay salaries of  EPA staff
responsible for  administering operator training programs.   The congressional
Conference Committee  on  Appropriations language  directed  that the  funds be
used to  improve municipal wastewater  treatment  facilities compliance, especial-
ly  in  small facilities, through  onsite training and technical  assistance.  Of
the add-on  funds,  $3,292,000 was awarded to 35 States.  Implementing Congress-
ional directions,   funds  were  allocated  to  States  based  on  the  following
criteria:

          o The majority  of the  funds  should be awarded to States with State
training centers  established under section  109(b) of  the Clean Water  Act or
other State authority;

          o Funds   should  be  targeted  to  small  Federally  funded facilities
(generally under  5 mgd effluent discharge) experiencing  compliance problems;

          o  A  diagnostic  evaluation  should  be  performed for each  facility
selected by the State to determine whether  compliance problems  were operator-
training-related and,  if  so, to determine the types of site-specific technical
assistance needed;

          o Onsite,  over-the-shoulder technical assistance  should  be provided
by  experienced  operations and maintenance personnel,  preferably State employ-
ees;

          o Followup  site  inspections  should  be conducted  to evaluate the
effect of training and technical assistance and  to  assure continuing perform-
ance improvement;  and

          o The  State should evaluate  and document  the training and technical
assistance efforts,  including before  and after facility  performance  and ef-
fluent data.

          In addition,  $575,000   was  awarded to  a  consortium of  the National
Demonstration Water Project (NDWP),  the National Environmental Training Assoc-
iation  (NETA)  and  the  American   Clean  Water Association  (ACWA)  for technical
assistance to  6 States;  and $67,200 was  awarded to the Association  of State
and Interstate  Water Pollution  Control Administrators  (ASIWPCA)  to summarize
and evaluate State operator training  programs.

         In FY  1983,  the  Congress added  $2,625,200  to EPA's  budget request.
Conference committee  language directed EPA  to continue  the policy direction
established in  1982.   The  language  also  required  the  Agency to conduct  a
.national study  through  a   national  environmental  training  organization  to
determine the  effectiveness  of  the  onsite  training  and  technical assistance
approach, to define the critical common elements of  effective  State operator
training programs  and  the  costs  of implementing such programs,  and to evaluate
the status  of  each State with respect  to achieving  programmatic and financial
self-sufficiency for operator  training.


                                      -7-

-------
     The majority  of  the FY 1983 funds were  awarded  to 48 States and 1 terri-
tory,  35 of which  had also received FY 1982 funds.  By the end of FY 1983, only
2 States, the other territories, and the District of Columbia were not partici-
pating in  this effort.  A  2-year grant was  also awarded  to NETA in  1983 to
conduct a  national program  evaluation.  Information  from the NETA project is
contained in the following sections on  overall State programs status; develop-
ment of model  State programs;  and Federal,  State, and local and private sector
action plans.

     The agency's  FY  1983 funding  guidance essentially  continued the  FY 1982
funding criteria.  However,  the Agency also  urged States to use a portion of
the funds to providp  financial management  technical  assistance  to  communities
in addition to  operator technical assistance, and to develop Statewide finan-
cial management  policy guidance.  This  additional emphasis  was based  on the
Agency's recognition that performance and  compliance problems are also caused
by inadequate local financial management and inadequate user charges for opera-
tions  and maintenance.   Improved financial management and updated local user
charge systems  are also critical to  improved compliance.  Limited funds were
also awarded to  selected States to describe  their operator training  programs.

     The FY 1984 appropriation  again provided  $2,625,000 to EPA to maintain
this effort.  The  Conference  Committee  also  directed  submission of a report
which  was submitted  by the  agency  on March  1,  1984.  Using FY  1984  funds, a
$500,000 grant was awarded to  NDWP to  continue  their  successful training and
technical assistance efforts and to work with selected States to assist opera-
tor training program development,  provide financial management technical assist-
ance,  and support  progress toward self-sufficiency.  A grant was also awarded
to NETA to work  with 13  States identified as  having  generally effective opera-
tor training programs  to  develop  individualized action  plans   for  achieving
programmatic and fiscal self-sufficiency.  These States also received supplemen-
tal grant funds  for needed program development support.  Allocation  of FY 1984
funds  to  States was completed  by March 1984 and all  grants were awarded by
September 30, 1984.

     A major objective and  accomplishment  in award  of FY  1982 and  FY 1983
funds  was to obtain maximum  State participation  in this program.  Award of FY
1984 funds was more selective.  The FY  1984 funds were targeted to  States that
had demonstrated a commitment to  this effort  as  reflected in funds  expenditure
and local compliance  improvement.   States  that had not  made  significant prog-
ress since award of  FY  1982 funds and that  had adequate  funds  remaining did
not receive FY 1984 funds. A total of 32 States received FY 1984 funds,  includ-
ing one State (Kentucky) that had not accepted a grant previously.

     Congress added $2,600,000  to EPA's FY 1985  budget.  These  funds  will be
allocated almost entirely to States  in  the near  future.  The  agency  intends to
use the same allocation approach as with the FY 1984 funds, emphasizing support
to selected States with demonstrated compliance improvement results and commit-
ment to onsite  training  and  technical  assistance  in  small communities.   A
portion of the funds will  be awarded  to NETA to continue assisting  development
of effective State operator  training  programs in 23  selected States. The ele-
ments of a  model  State  program are described in detail in the State Action
Plan section of this report.
                                      -8-

-------
      B.  Status of Grant-Funded Projects

          Attachment B  lists  State accomplishments  to date in  each community
provided assistance using 1982 or  1983  section 104(g)(l)  grants.  Attachment C
provides State-by-State  funding  status,  diagnostic  inspection and technical
assistance commitments, and summary accomplishments to date.

           States awarded FY  1982  funds have generally completed  the majority
of their work in most of the initial communities selected for technical assist-
ance.  However, most  of the  grants provide  for extended  followup monitoring
and assistance  through FY  1985.  Most  States  experienced  startup delays  on
their initial  grant (in FY  1982  or 1983}  averaging  9  months for staffing,
internal State  coordination  and  approvals,  and grant-funded  procurement  of
minicomputers and  diagnostic  modeling  programs. As  a  result, even  some  FY
1983-funded work programs  are just  completing the problem diagnostic  evalua-
tions in  communities  prior  to  selecting  plants for  onsite training.  Grants
using FY  1984  funds were generally not awarded  until  late  September 1984,  and
work has not been initiated in any of the additional communities.

           Based on negotiated FY  1982 and FY 1983 grant work plans, funds were
provided to  48 States  and  to the National Demonstration Water Project (NDWP)
to conduct  over  1,100 facility  problem  diagnostic  inspections,  to  provide
onsite technical assistance and training  at about 850 small  facilities,  and
to develop 10  Statewide financial management guidance and assistance programs.
The funds awarded  NDWP supported  a 2-year  technical  assistance demonstration
project in  six  southern  States,  including  West  Virginia,  South  Carolina,
Tennessee, Mississippi, Louisiana, and Kentucky.

           The information  from  States and the  NDWP project indicates  the
onsite training and technical assistance program efforts  are achieving impor-
tant compliance improvements  and demonstrating the  value  of training and tech-
nical assistance to these small communities. Operators in a total of 842 plants
are being provided training and  technical  assistance.  States are still working
in 412 of these plants.  As of November 1984, full compliance has been attained
in 352  of these plants with  significant  performance  improvement  shown at 132
additional plants.  With the  exception  of  a  few plants where design, construc-
tion, or major institutional problems preclude a training and technical assist-
ance solution,  the agency  expects that essentially all  of these  plants  will
achieve compliance  by  the  end of  FY 1985.   The data also show  that the onsite
assistance is:

           o  Improving  local decisionmaker  involvement  in plant  operations
              and maintenance and  financial management;

           o  Improving treatment  process control management;

           o  Introducing preventive maintenance programs  and  ensuring repair
              of equipment;

           o  Reducing energy and  sludge-handling costs;

           o  Improving  laboratory, recordkeeping, and  reporting  practices;

           o  Improving infiltration/inflow management; and

           o  Identifying operator certification and continuing education needs.

-------
          Evaluation of the NDWP and State efforts has also identified a number
of issues and pitfalls  for States to avoid.  Evaluation has  indicated the  im-
portance of:

          o  Problem diagnostic modeling and inspections to assure that problems
             relate to training rather than to design or  financial  management;

          o  Good effluent,  monitoring data and reports upon  which to  base an
             evaluation of compliance improvement;

          o  Effective local treatment and financial management and  community
             recognition of compliance problems;

          o  Onsite  followup  to  ensure  continuing  attention  to  problems;

          o  State coordination and  support,  including compliance  actions, to
             reinforce operator  training,  operations  and maintenance,  user
             charge,  and effluent monitoring/reporting requirements.
                                      -10-

-------
IV. STATUS OF STATE OPERATOR TRAINING PROGRAMS

    In support  of the  March  1984  EPA  Preliminary Report,  ASIWPCA  and NETA
queried States on organizational structure; budgets; staffing; training program
objectives, procedures,  and requirements;  and  future training  directions and
needs.  Appendix  D reflects updated  data on current  programs  in  all States.

        A.  State Organization

            Operator training  programs  are  conducted  primarily  through  State
environmental agencies and  State 109(b)  or other established training centers.
Within the State agencies,  training may  be a  separate  organizational function.
More often, operator  training  functions have been  integrated into the compli-
ance or  construction  grants program  management organization.   Even where the
State 109(b) training  center is identified as  the  lead  State entity, training
also occurs  within other  elements  of  the water  pollution  control program.

            State water  pollution control personnel  often  exercise multiple
responsibilities, including  operator training,  delegated  construction  grants
management, operations and  maintenance,  and compliance and enforcement. Train-
ing personnel may be involved, appropriately for integrated program management,
in conducting facility plan and specification  reviews;  providing  facility start-
up services;  and  conducting  operations  and maintenance   reviews,  compliance
evaluations, and compliance  inspections.   Staff directly responsible for these
activities also may provide onsite technical assistance and informal training
to operators while working with new  facilities concerning performance certif-
ications or while conducting compliance evaluations.

          Section 109(b)  or other training centers  generally  are associated
with State junior colleges or vocational education institutions under the State
education departments.   Their  responsibilities  may  include Statewide training
coordination.  These centers are usually training  resource centers and provide
primarily entry-level/certification and upgrade training.  State departments of
health also  have  significant  direct  or  coordination  responsibilities  in  a
number of States relating to operator certification training.

        B. Training Program Administration

           As State training programs have  matured, program objectives and re-
source allocations have  expanded to  include continuing education and technical
assistance as well as  operator certification. Although  there are a wide range
in individual  categories among  the  States,  the  "average"  State's priorities
and resources are distributed as follows:  certification 25 percent, continuing
education 30 percent,  technical assistance 35 percent, and support to construc-
tion grants  management  and permitting  10 percent.  The  levels  of technical
assistance are  being   influenced  by  section 104(g)(l)  funding  guidance,  but
increased technical assistance  emphasis  coincides with the  direction  States
want to  take.  The  percentages of  resource  commitments to  certification  and
continuing education training  are also  skewed  slightly because a  few States
reported technical assistance and support  to other programs  in these categories.
                                                          U.S. EPA Headquarters Library
                                                                Mail code 3201
                                                          1200 Pennsylvania Avenue N W
                                                             Washington DC 20460

-------
           All States  have  operator  certification  programs and  nearly  all
States  (44) have mandatory certification requirements.   Operator certification
requirements are  generally  similar among  States,  providing  four classes  of
certification based on the size and complexity of facilities.  However, nation-
wide, approximately  25 percent of  operators are not certified and,  based  on
1983 data,  40 percent  of operators  were  not  certified  for their  levels  of
operations responsibility.   States report  a total  of  about  96,000  operators
nationally.  Of  the  approximately  73,000 certified  operators in the States,
approximately 40 percent receive continuing education annually.  These continu-
ing education courses  are  usually of 1  to  2 days duration;  States  offer 30 to
60 courses annually.   States are increasingly expanding certification require-
ments to  include continuing education  and  knowledge of  industrial  wastewater
treatment processes.  Some  are  also  considering   requiring  testing  of  both
wastewater treatment theory and demonstrated performance.

          States also  report  redirection  of their  training programs  toward
achieving improved  compliance.   Shifts from prior  emphasis  on training  for
certification or upgrade  as primary  objectives  are  becoming  apparent.   These
results-oriented approaches  by  States to program management are  fully consis-
tent with EPA and congressional objectives.


        C.  Funding

            States report  total FY  1984 operator training budgets  of approxi-
mately $10.2 million.  About  19 percent  or  $2 million was from  local sources,
38 percent or $3.8 million from State  sources, and 43  percent or $4.3 million
from Federal funds.

            Total annual  State training budgets range from  $25,000 to  over
$900,000, average about  $200,000,  and  are  generally in the range  of $100,000
to $400,000.  The  majority  of  funds in State  budgets are  composed  of  State
appropriations and Federal grants under  Clean Water Act sections 106,  205(g)
and 104(g)(l).  Although State budgets often have some local-funding component,
usually tuition  and  fees,  the local portion generally does  not represent  a
significant part of most individual State budgets.  A total of 34 States receiv-
ed less than  25  percent  of  funds and 43 States received less than  50 percent
of funds from local sources  in  1984.  However, five States received  all  or the
majority of  funds  from  local  sources. These  include  Ohio,  North  Carolina,
Pennsylvania, Florida,  and Oklahoma.   Although  not  reflected above,  support
fron local funds generally appears to  be most  significant in western States.

            Only 7 States have  no direct State appropriations and 7 additional
States obtain less than 20 percent of funds from other  sources.   Only 9  States
report more than  50  percent  of budget  from State  funds.   The percentage  of
State funding to total annual funding ranges  up to  71 percent  in  2 States  with
an average of slightly over 29 percent. A total  of  23 States receive less than
50 percent of funds from  Federal  sources.  Of  the remaining States, only  12
States obtain more  than  75  percent of budgets from Federal funds.   Federal
funding is obtained  primarily  from State  agency   allocations of section  106
State program grants or  State targeting of available section  205(g)  construc-
tion management  grants.    Section  104(g)(l)  add-on  funds have  represented  a
significant additional funding source   since early  FY  1983  in  many  States.
                                      -12-

-------
            There is a wide  range of State training  investment  on a per-oper-
ator basis. Annual  spending  per operator  ranges from about S15  to over $550,
with an average of about S160 per operator. Overall, States with relatively few
operators, States with a technical  assistance emphasis,  and States with larger
annual budgets tend to spend more per operator than other States.

            The agency believes the  available  funding  information underesti-
mates total State  contributions to operator  training  programs.   The operator-
training-related activities by State construction grants management, operations
and maintenance,  and compliance  and enforcement personnel  are  generally  not
included in these budget figures.   Based on overall data,  the agency believes
that the support provided  by these programs may represent  a significant addi-
tional contribution to the total State training program.

            State self-sufficiency, as defined by EPA,  is the ability to main-
tain an effective operator training program using only  local  tuition and fees
and State appropriated funds as necessary.  From reviewing  State program des-
criptions, it is clear that  only a few States approach  a comprehensive, inte-
grated, and  self-sufficient   training program.  However,  a  number  of  States
also appear to be moving toward  improved  overall programs,  to increasing State
funding, and to developing cost-based local tuition and  fee  systems for self-
sufficiency.

            The agency continues to support the objective  of  full State/local
self-sufficiency.  The agency  also  recognizes  that Federal funding  should  con-
tinue to  support  the development  of  overall effective,  integrated municipal
compliance programs,  including  operator  training  and  technical  assistance,
until States can achieve and maintain self-sufficiency.  In  1984,  Federal funds
supporting State municipal and  industrial permitting  and  compliance totaled
approximately $32 million.  Federal funds  for operator  training  and technical
assistance totaled  approximately  $4.3 million  from  both  sections 106  and
104(g)(l) add-on funds.

        D. Staffing

           Many States rely  heavily on part-time trainers,  both  salaried  and
volunteer. A total  of 75  percent  of the  786  staff  reported were part-time.
This is  particularly true  in  large  States  such  as  New York,  Pennsylvania,
Illinois and Minnesota that have a total of over 300 part-time trainers.  States
average about 4 full-time trainers, with a range of zero to 19.  In most States
these trainers have a significant number of years of  experience.  Qualifications
of staff  include  professional engineering, training/vocational  education,  and
facility operations, obtained  both  academically  and on-the-job.   The part-time
trainers are generally responsible  for  short-course  continuing  education  and
onsite technical assistance.   The  full-time trainers  are primarily responsible
for training-center administration, materials  development,  certification test-
ing, and entry-level  training through the State departments  of  education  or
health.
                                      -13-

-------
V.   CONCLUSIONS

     Since  submission  of  EPA's  Preliminary Report  to  Congress  in  March 1984,
the  agency has obtained  and  evaluated updated  status  and accomplishment data
from States and  has worked with a  work  group to formulate the conclusions and
recommendations contained in this  report.  The conclusions  and  action plans
that follow reflect their views  as well as  EPA's.  The following information
describes  A)  the  appropriate  roles  and  responsibilities  of  each level  of
government and the  private sector  for operator training and  improved  compli-
ance; B) the  elements  of model  State operator training and conpliance programs
that support  these  roles  and responsibilities; and C) proposed multiyear action
plans for  activities at each level  of  government and by the private sector for
improved operator  training,  effective operations  and maintenance,  and permit
compliance.

     A.  Federal,  State,   Local  and  Private  Sector Roles  and  Responsibilities

        Stated as  goals  and objectives,  the  following  outlines complementary
Federal, State, local and private sector roles and responsibilities for achiev-
ing  improved  municipal  facilities   compliance.  The definition of  roles  and
responsibilities is provided as a basis for  developing  a  model State operator
training program  and  for defining   Federal,  State, local,  and private-sector
action plans  to  achieve  improved   overall   municipal  facilities  compliance.
Because improved operator training  programs are only one  element  in achieving
the  overall  objective,  these roles and responsibilities relate to other needs
at each level of government.

         1. Federal

            a. Goal

               To achieve  improved  water quality  through implementation  of
effective Statewide programs  that  provide  for coordinated  operator training,
operations and maintenance management, and enforcement.

            b. Objectives

               o  To provide Federal oversight to implementation of the National
Municipal Policy and State-local efforts to ensure coordinated, com-
pliance-oriented programs.

               o  To promote development of  State  self-sufficiency to maintain
effective operator training programs through  State-local fee systems and State
appropriated funds  approaches (and  financial assistance under  sections 205(g)
and  106 of the Clean Water Act).

               o  To increase local awareness of statutory requirements through
construction grants, permitting,  and  operator  training  activities,   and  the
cost-effectiveness of operator training and improved operations and maintenance.

                o  To  promote  maintenance of local  financial management  and
user-charge systems  that recover  current costs  of operations,  maintenance,
routine equipment replacement,  operator training, and facility expansion needs.
                                      -14-

-------
               o  To  provide  technical  and  program management  assistance and
information to local  officials,  facility operators,  and private  sector consul-
tants and  trainers  to ensure  use of  appropriate,  cost-effective technologies
and improved operating facilities compliance.

               o  To  support use  of  section  109{b)  or State funds to construct
State training centers that provide  an institutional focus  in the State, com-
prehensive operator training,  and onsite technical assistance.

               o  To  support use  by  States of sections 205(g) and 106 funds to
assist their transition to full State self-sufficiency.

               o  To  promote  communication among States,  municipalities, pro-
fessional associations,  interest  groups,  and  the  private  sector to  create
public awareness  of  the  importance  of operator training, to share ideas, and
develop coordinated  approaches for  improved municipal  facilities compliance.

               o  To promote operator professional status, certification,
training, and  local  salary  structures  that  attract  and  retain  qualified
personnel.

            2. State

               a. Goal

                  To ensure municipal  facilities  compliance  through comprehen-
sive, coordinated, and  self-sufficient operator  training  programs;  operations
and maintenance programs;  technical  and  financial  management assistance pro-
grams; and enforcement programs.

               b. Objectives

                  o  To develop strategies to bring noncomplying facilities in-
to compliance using  training  in  conjunction with  other State  activities and
local communities to achieve National Municipal Policy requirements.

                  o  To provide Statewide policies,  guidance, and standards for
local governments on operations  and maintenance, user  charges,  and  operator
training and certification.

                  o  To monitor municipal  facilities compliance  and to respond
to evidence of  noncompliance  in accordance with  the National Municipal Policy
with appropriate technical assistance, training, and compliance actions.

                  o  To identify and implement appropriate self-financing mech-
anisms, including user-fee  systems  and  appropriated State funds,  in  order to
maintain adequate local utility management and effective  Statewide operations
and maintenance oversight,  operator training, and  technical assistance programs.

                  o  To establish and implement an  institutional  focus in the
State for training and Statewide compliance-oriented programs that provide for
certification and inservice training and onsite techical assistance.


                                      -15-

-------
            3. Local

               a. Goal

                  To construct, operate, and maintain publicly owned wastewater
treatment facilities that comply with design and effluent requirements and that
become  self-sustaining utilities.

               b. Objectives

                  o  To  prepare necessary  compliance  and correction  plans to
ensure  that the municipality can achieve and maintain compliance.

                  o  To  ensure that  proposed  wastewater treatment  facilities
are within the  community's financial management capability,  can meet effluent
requirements, and are operated and maintained effectively.

                  o  To ensure  that  financial  management and user charge sys-
tems are  established and  maintained that  identify and  recover the  costs of
operations, maintenance, routine equipment  replacement, operator training, and
expansion needs.

                  o  To ensure that facilities are staffed by operators trained
to operate and maintain  the facilities  in compliance with  requirements and
that salary structures and the working environment attract and retain qualified
and certified operators.

                  o  To administer and enforce pretreatment requirements.

            4. Private Sector

               a.  Goal

                   To maintain a competent  work force, available as  needed, to
provide operations and maintenance assistance  to  facility owners and State and
Federal agencies on a contract basis.

                b.  Objectives

                    o  To develop diagnostic  services  and procedures  aimed at
identifying the  factors at  a  facility that  are  preventing  compliance  with
discharge requirements
that are  performance
training needs
To  develop and maintain  training  delivery capabilities
based  and  geared  to facility-  and  operator-specific
                     o  To  provide  operations,  maintenance,  and  management
services by maintaining personnel who  can,  for a period of time, assume direct
operational control of  a wastewater treatment facility to  restructure opera-
tions and  maintenance  procedures  and  change  behavior  through  demonstrated
performance

                     o  To actively  participate in  local,  State,  and  Federal
operator training and technical assistance programs that support the continuing
upgrading and professional status of operators.
                                      -16-

-------
    B.   Model State Operator Training Program

         Hie following describe the  overall  functional and process elements of
a model  Stat« operator  training  program.  An  effective  program is  one  that
implements defined  State  roles and responsibilities for  operator  training,
improved local operations and maintenance and permit compliance.  The definition
of these elements are the result of  intensive analysis by NETA and review  by a
task force composed of State, local, and EPA representatives.

     A model compliance-oriented State program includes:

         1. Integrated Compliance Program

            Operator training and technical assistance should be  integrated in-
to the  State's overall  water pollution  control program.  A coordinated,  and
ultimately fully  integrated,  system should be  established to provide formal
communication and organizational  links between  training  and technical assist-
ance programs with  operations  and maintenance,  compliance and enforcement, and
construction grants  programs  in the State.  In addition,  the  use  of private
sector support, including consultants and  State operator associations, as well
as peer matching, local  cooperative  arrangements, and  self-help systems should
be encouraged and assisted.  An  integrated system  should ensure coordinated,
timely, and most  appropriate responses to  noncompliance,  create incentives for
compliance and improved  facility management, provide the  means to help resolve
training-related plant performance problems, and provide  mechanisms  for annual
evaluation of results.

            A formal  coordination  ccnmittee,  composed  of  representatives of
all appropriate State  agencies, should meet quarterly to identify  plant per-
formance problems throughout the  State to assign  responsibility  for training,
technical assistance  or informal/formal compliance  action based on diagnosis
of the problems and ensure  continuous followup  and  feedback on  results.   One
lead agency  should  be  identified  by the  State to  coordinate and  manage  the
overall effort. In  the  long term,  the State regulatory  agency  appears  to be
the most appropriate organization to manage these functions.

            The State program should  also  ensure operability and maintainabil-
ity reviews of proposed  plant  designs and specifications; use  of startup ser-
vices; review of O&M manuals and development of useful manuals; use of diagnos-
tic evaluations; and  support  to Composite Correction  Plan (CCP)  and Municipal
Compliance Plan (MCP) development and implementation under the National Munici-
pal Policy.

         2. Assessment of Training and Technical Assistance Needs

            Training and  technical   assistance  needs  assessment   should  be  a
continuous process.  However, the  State agency should  formally  assess  needs at
least annually, with quarterly updates that coincide with review  of  compliance
reports.  The needs assessment should be  based on  feedback from  the formal
interprogram coordination process above as well as  on deficiencies  identified
in problem diagnostic  and  compliance  inspections.    Ongoing training  needs,
including entry level  and  inservice training  needs,  should also be  part  of
the needs  assessment.   The  needs assessment  should  be  based  on  diagnostic
evaluations of compliance problems and determination  of  the types,  quantity,
and procedures for  technical assistance  and training  needed  by each community
and operator.
                                                                U.S. EPA Headquarters Ubrary
                                                                      Mail code 3201
                                      -1                        1200 Pennsylvania Avenue NW
                                                                   Washington DC 20460

-------
       3. Action Plan

         An annual  action plan should be developed linked to the needs assess-
ment as  well  as  feedback from the trainers  and trainees.  At  a  minimum, the
action plan  should identify and  set  priorities for who  will be trained, what
training and technical assistance will be provided, who will provide it, how it
will be  provided,  and the source(s) of  funding.   The  action plan should serve
as a primary basis  for developing and justifying annual budgets.

       4. Training Delivery System

         A delivery system  should  be developed  and coordinated  among State,
local, and  private sector training entities.  The  system should  reflect all
aspects of training delivery,  including conventional and on site  instruction,
curricula, instructor qualifications, delivery methods,  technical content, and
training materials.   States need to  manage and  coordinate training delivered
directly through  State  training centers and other  State agencies and by the
private sector to ensure that programs meet  identified  needs and are  oriented
to assuring compliance.  The  training program  and delivery system should ensure
a balanced mix of entry level and inservice training and technical assistance.

         The State  should establish quality control criteria for courses, and
training and technical  assistance materials; provide training materials based
on "need to  know"  criteria; periodically  evaluate courses,  materials  and in-
structors; and  maintain   and  disseminate  a  list  of  approved  courses  and
materials.

         The delivery system should  encourage development of local peer match-
ing, cooperative arrangements and other  self  help systems and use of nontradi-
tional methods, such  as mobile training facilities, hotlines,  circuit riders,
minicomputers and other remote audiovisual delivery.

         State training  centers exist in 28 States,  the majority of which were
established under  section 109(b) of  the Clean tfeter Act.  Several additional
States are also  considering or  in  the  process of establishing centers. These
centers can serve as an  institutional training  focus for the State, as well as
a primary source  of training delivery.  However,  State  training centers, typic-
ally located in State education departments,  must support identified Statewide
needs, priorities and policies; operate  in  close  coordination with State regu-
latory agencies;  provide  a  Statewide  delivery  capability;   and  maintain  an
outreach program particularly for small community assistance.

      5. Mandatory Operator Certification

         Most States  (44)  now have  mandatory  certification  programs.  These
programs, however,  usually do not measure  operator competency  to operate and
maintain the specific facilities  in  the  community,  require  annual  inservice
training to maintain certification, or assure  that operators are certified for
their levels of responsibility in the plant.  An effective mandatory certifica-
tion program should provide that operators  demonstrate in-plant competency,  be
certified for operation  of the appropriate treatment  process, and obtain in-
service training and recertification as appropriate.
                                      -18-

-------
      6. Management Information System

         A management  information  system should be maintained to support inte-
grated compliance  efforts,  training  needs  assessment, training  and technical
assistance delivery priorities and approaches,  documentation of  results,  and
program evaluation. The system should document the compliance results of train-
ing and  technical assistance  for  feedback  to  compliance  response decision-
making; maintain  records  of operator certification status,  training obtained
and needed;  be used  to  notify  communities  of requirements;  and  maintain  a
list of approved courses.

      7. State Staff Training

         To provide  effective  operator  training  and  technical  assistance,
State training  staff   need  to maintain  and  upgrade their  own technical  and
training skills.  States  should ensure that  funds are provided  for train-the-
trainer workshops  and  conferences, professional development, and  purchase of
materials.  Recognizing that training is also provided in most States  by per-
sonnel in regulatory and  construction grants programs, training also should be
provided to  these State  personnel in training  approaches and  in  identifying
plant performance  problems  that can  be  solved  through  training or technical
assistance.
      8. Public Education

         Achieving improved  plant performance  and compliance  depends heavily
on how  well  State and  local  decisionmakers and the  general public understand
and support  the  importance  of  effective  wastewater  treatment,  the  level  of
public capital  and  operations and  maintenance investment  in the  plant,  local
compliance responsibilities under  the  National Municipal Policy and  the  Clean
Water Act, and  the  need for  operator  training.  The State  should maintain an
ongoing education effort targeted  at local officals and  the general  public to
promote improved understanding and political and financial support.
      9. Adequate Long-term Fiscal Support

         Long-term funding  mechanisms must  be established  and  maintained to
support effective  training and  assistance  programs. The  funding  mechanisms
should emphasize achievement  of self-sufficiency  through local user  fees and
dedicated State funds.   Federal  funds,  under sections 106, 205(g),  and poten-
tially 104(g)(l) of  the Clean Water  Act,  should be  used to  develop effective
programs and,  to  the  extent  necessary, to  maintain effective  programs until
programmatic and fiscal self-sufficiency is achieved.

         The costs  of  implementing  an  effective program  will  vary  signifi-
cantly among  States depending  on  their current  programs and  current  mix of
local, State,  and  Federal  funds.   Appendix D documents  the range of types and
levels of programs  among the  States.  A  few States  are presently very close to
implementing the full  range of elements and  achieving self-sufficiency.  Other
States have reasonably effective programs  that  would require  relatively little
additional program  development,  State and local  investment,  and  time  to meet
objectives.  There are also a number of States with very limited programs and
budgets that will  require major program,  statutory, and staffing adjustments
and an extended period of time to do so.

                                      -19-

-------
         The agency  has provided funds to NETA to  develop and test a workload
and  costing methodology,  based on these elements of  quality training,  to help
States and EPA develop estimates of  implementation costs.  The draft model and
pricing methodology  is presently  being tested  and evaluated  in  a  number  of
States and only preliminary data are  available.  The  data  from  11  States show
incremental costs  ranging from  less  than  $10,000 to more  than  $450,000  on an
annual basis.  The  incremental costs vary  significantly  because  of the current
status of  the  State program  and the  number and  size  of facilities  in the
State.  The  total  cost of  a model  training program in  these  selected States
ranges from $950,000 in a very  large  industrial  State to  $165,000  in  a  rural
western State.  The average incremental  cost of the model  program in these 11
States would  be approximately $200,000  annually.  The national  annual  cost  of
the  model  State program,  based  on  the average of  this  small  sample, would be
about twice  the  total  1984   cost  of  the  current  programs  in  the  States.

      C. Action Plan

         Following submission  of the Preliminary  Report to Congress in  March
1984, EPA  convened  a  working group of  State,   local,  and other appropriate
officials to  define  realistic  short-term  and  long-term  policies,  programs,
and  activities,  consistent  with agreed  on  Federal, State,  and  local  roles
and  responsibilities  for  ensuring  improved  municipal  compliance.  Although
this plan has  been coordinated  within the Agency and with representatives  of
State and local interest groups, and  reflects broad agreement  on the framework
and many  individual elements,  the  plan  does  not  represent  a commitment  by
States or local governments to implement all needed actions  in the near future.
Given resource  and other constraints  to some of the actions,  the  wide  range
of existing programs at State and local  levels, and the  number of governmental
entities involved, the agency  believes that  identified State and local actions
will likely be  implemented over an extended period of time.

         Meeting overall municipal  compliance objectives,  including effective
plant operations,  maintenance,  management,   operator training  and  technical
assistance requires  a  comprehensive management approach  to the  problem at all
levels of  government.   Improving operator training  and  technical  assistance
programs is an integral part  of the  needed strategy, but these  programs can
address only those municipal  compliance problems that can  be  resolved through
improved operations  and  maintenance.  Effective  programs  must also rely  on
enforcement and  overall operations  and  maintenance  incentives. Programs must
also recognize  that significant design, construction,  and laboratory capability
problems also exist  that  cannot be  resolved through  training,  and may not  be
solved through enforcement.

      The EPA,  State,  local and  private sector  action  plans that  follow are
built on the  above  assumptions.  The plans  first define a number of  overall
management actions that  are needed to coordinate with and reinforce training
and  techical assistance program  efforts. The action plans then identify opera-
tor  training-specific  actions that  should  be implemented at  each level  of
government.  The actions  listed  do  not assume any  prerequisite  actions by EPA
or States.
                                      -20-

-------
           1. Current EPA Actions

              EPA has  a number  of  activities underway  to  improve  municipal
treatment facilities compliance  and that support operator  training needs.  In
addition to working closely  with various national organizations, EPA is manag-
ing the  congressional  add-on  section  104(g)(l)  funds  to meet  congressional
directives and agency compliance improvement objectives.  The agency and States
are implementing the requirements and  intent of the National Municipal Policy.
The agency is already beginning  to  implement  several  of the actions called for
in the  following  section including  establishment of awards  programs,  issuing
new program  coordination policies  and  guidance,  developing new  information
materials, working  with  interest  groups  and  professional  associations,  and
targeting available funds and  staff resources to improved operations and main-
tenance.  The  agency  is  also now  considering  other  compliance  and  funding
initiatives.  The agency  is  also incorporating operations  and maintenance in-
centives into  a  study  it has  conducted on  future Federal funding approaches
to wastewater treatment facility construction.

             Computer diagnostic modeling  programs are  being enhanced to im-
prove front-end identification of  design and  operations  and  maintenance  prob-
lems and to target operator training and technical assistance.  A complementary
financial/organization management diagnostic  model  has  also  been developed to
help communities identify issues in these  areas that affect plant performance.

             A national training conference  was  conducted  in  May  1984.   The
conference was directed primarily  to State and EPA training  officials  respon-
sible for administering grant-funded programs to exchange information on train-
ing needs,  technical   assistance  approaches,  training  delivery issues,  and
accomplishments to date. A  second national  conference  is being  scheduled for
June, 1985.

            The agency  is also  issuing local financial  management guidance and
assistance materials  to  help  ensure   improved   facility performance  through
first-year grantee  performance  certifications.   Revised construction  grants
program management, delegation management, secondary treatment regulations, and
a financial management capability policy also have been issued.

           2. Additional EPA Actions

              a. Overall EPA Management Actions

                 o Issue agency  policy requiring enforcement of O&M require-
ments in permits.

                 o Maintain  internal  EPA coordination  to ensure  consistent
interpretation and implementation of National Municipal Policy.   Ensure opera-
tor training and  technical  assistance  are  included as integral  components of
Composite Correction Plan (CCP) development and implementation.

                 o Promote improved coordination and organizational integration
of State  enforcement,  O&M,  training,   technical  assistance,  and construction
grants programs through policy, guidance, and grants management.

                 o Require annual or biannual independent audit of local finan-
cial management  systems and update  of user charge  systems by noncomplying
communities to ensure  funding  of effective operations and maintenance,  includ-
ing operator training.


                                      -21-

-------
                 o Require  that States  include adequate startup  services and
process management  laboratory equipment  funding  in all  new  facility  grants.

                 o Maintain adequate EPA staffing to provide needed State/local
O&M/operator training  programs  assistance  and coordinated,  results-oriented
State oversight.

                 o Develop  and  disseminate information  materials to  States,
grantees, and communities  not expected to receive Federal funds on cost-effec-
tiveness of  good operations,  maintenance  and  management?  low  cost  treatment
technologies? and treatment cost-reduction approaches.

                 o Establish  EPA awards programs and  promote  establishment of
State and local  operator awards programs to recognize and encourage  effective
plant operations and maintenance. Disseminate information on State O&M subsidy
programs.

                 o Request  legislative  changes  to incorporate  significantly
weighted O&M element  in State  construction grants priority systems  criteria.

                 o Establish  high priority  for use  of  State grant  funds to
develop and  implement  improved  operations  and maintenance, operator training
and technical assistance programs  that support  overall municipal  compliance
priorities.

              b. Operator Training - Specific Actions

                 o  Issue O&M and operator training policy and guidance coordi-
nated with permits and enforcement policy to encourage development of coordina-
ted Regional  and  State  programs and implementation  of  compliance-oriented
operator training.

                 o  Expand  work  with  interest  groups,  professional  associa-
tions, other organizations,  and  other Federal agencies providing  wastewater
treatment funding to  develop  increased awareness  and support to compliance-
oriented training and technical assistance. Consult with representative  State
and local officials on the development of consistent, coordinated O&M,  training,
and technical assistance policy and guidance.

                 o  Compile and disseminate information  for  States  and  local
governments on the  compliance  improvements obtained  as  a result of training
and technical assistance and  on feasible approaches to establishing effective,
self-sufficient facility O&M and operator training programs.

                 o  Target Clean Water Act  sections 106,  205(g), and 104(g)(l)
add-on funds to development  of effective,  self-sufficient  State  training pro-
grams that support  overall municipal  compliance  objectives.   Condition grants
as necessary to ensure priority implementation.

                 o  Identify levels and duration  of needed Federal funding to
support development  and  implementation  of operator   training  and  technical
assistance components of State municipal compliance programs.

                 o  Promote use of  205(g)  and 109(b)  funding authority  for
development of improved State outreach training capabilty.
                                      -22-

-------
                 o  Provide  treatment facility diagnostic  modeling capability
to States to  assist  in identifying compliance  and operations management prob-
lems and related training needs.

                 o  Develop and disseminate criteria and costing approaches for
establishing effective  State  and  local  training  programs  and  assist  State
implementat ion.

                  o  Promote  increased private sector  involvement  in training
through the  Water Pollution  Control  Federation,  other professional  associ-
ations, and the EPA Management Advisory Group.

              c. EPA Implementation Requirements

                 The agency is already implementing several of these actions and
is now considering early action on a number of others.  With only a few except-
ions, EPA can  implement  these needed  actions within existing statutory author-
ity.  There are  seme  resource constraints to implementing  all  of  these recom-
mendations in  the  very near  term,  but the  agency is generally supportive  of
early action  to  improve  operations and maintenance  and operator  training  in
conjunction with other municipal compliance efforts.

           2. State Actions

              EPA has been  working with representatives of NETA,  ASIWPCA,  the
National Association of Towns  and Townships  (NATaT), and  selected  other offic-
ials to define the critical, common elements of effective State operator-train-
ing programs, and the costs of implementing effective programs.

              The following  functions and activities comprise  the  agreed ele-
ments of a fully effective  State operator training  program, including  compli-
ance and  operations and  maintenance  program relationships,  and   represent  a
recommended action plan for State program development.

              a. Overall State Management Actions

                 o  Establish  and  maintain  formal interagency coordination and
organizational integration  mechanisms among  State O&M  and  operator training
programs with enforcement/permits and construction grants programs.

                 o  Issue  coordinated  Statewide   policies  and local  guidance
using all  program  authorities,   including  training  and technical  assistance
programs in  addition  to  enforcement  under the  National Municipal  Policy,  to
bring communities into compliance quickly and effectively.

                 o  Require, where lacking, minimum analytical laboratory
equipment in all facilities and  train operators  in treatment  process  control
management.  Ensure adequate  laboratory  capability exists onsite  or  through
certified contract  labs   for effective NPDES permit  effluent monitoring  and
reporting.

                 o  Provide  communities  with  financial management  and  user
charge guidance and assistance prior to facility construction.
                                      -23-

-------
                  o  Require corrmunities  to establish sound financial management
 systems to monitor  and to  recover current  costs of  operations, management,
 equipment and facility  repair  and replacement,  training,   and  construction.

                  o  Implement  information  programs to  increase  awareness  of
 local officials  and  operators  of statutory requirements and  cost-effectiveness
 of O&M and training.

                  o  Conduct operability  and maintainability reviews of proposed
 construction  designs and  specifications to  prevent  O&M  compliance problems.

                  o  Encourage  local review  of operator salary structures and
 working environment  to  ensure  communities  dan  attract  and  retain qualified
 personnel.

              b.  State Operator  Training-Specific Actions

                  o Assess  needs annually. Develop results-oriented State
 training, O&M,  and  compliance  strategy  and action plan  that  assigns  roles,
 responsibilities,  priorities,  and  resources  annually and  provides  the basis
 for coordinating  needed  technical assistance, training, and enforcement.

                  o Reorient  and  expand  State  training  programs,  including
 training centers,  to a compliance-results orientation.

                  o Establish onsite training and technical assistance programs
 for small  noncomplying   communities' management officials and operators using
 Federal, State,  local,   and  private sector  resources;  help  local governments
 develop network arrangements among  sources of assistance.

                  o Maintain effective conventional classroom training programs.

                  o Implement and and enforce mandatory competency-based opera-
 tor certification and  upgrade training  programs.   Evaluate  training materials
 and recommend the most useful to communities.

                  o Conduct computerized and onsite facility diagnostic evalua-
 tions to identify training-related problems, design and  construction problems
 not susceptible  to a training/technical assistance solution,  and enforcement
 needs.

                  o Incorporate  and enforce O&M  and training requirements  in
 permits and construction grants.

                  o Use  Federal  106,  205(g),   104(g)(l), and 109(b)  funds  as
appropriate to develop and  implement effective State O&M, training, and techni-
cal assistance programs.

                  o Examine and  implement appropriate State-local funding mech-
anisms  to  achieve programmatic and fiscal  self-sufficiency  and  earmark funds
to meet  identified operator training and technical assistance needs.

                 o Promote expanded private sector (i.e., consultants,  opera-
tors, nonprofit  and  volunteer)  O&M  and  training  role,  especially  in  small
communities, through  contracted  O&M  and  laboratory  support,  circuit-rider
training, peer match or contract technical assistance, computer modeling,  and
audiovisual approaches.
                                      -24-

-------
              c. State Implementation Requirements

                 Because State programs  are  at different stages of development
and operate  under different  constraints, every  State  will not  need  to,  or
choose to, make  significant  early changes to current programs.  The agency has
provided funding to ASIWPCA  and  NETA to evaluate the  current status  of State
training programs.  EPA  has  also provided funding  to  NETA  to  compare current
State programs  with  the  elements of  the model  program and to work  with  at
least half of  the  States during  the next  two  years to assist them directly  in
developing an  action  plan to  implement  needed changes. The remaining States
will be provided  information from the States  assisted  directly on approaches
for achieving  more effective programs.   Implementation of  effective,  compli-
ance-oriented programs  in half  of  the   States can probably be  accomplished
within five  years.  Although EPA  and ASIWPCA intend to  encourage  early needed
action in all  States,  given the  status  of  current operator training programs
in other  States,  implementation  in all  States will probably require  at least
ten years.

           3. Local Government Actions

              Local governments have the primary  responsibility  to achieve and
maintain compliance through  effective  operations  and  maintenance,  financial
management, and  operator training.   Data tend to  show that  the  majority  of
noncompliance is  now  in  small  communities  with  facilities discharging  less
than 1 million gallons  per  day.  These  small communities  tend to have  more
training needs, more financial problems, and consequently more  operations and
maintenance problems.    They  also generally have  received  low priority  for
enforcement and  little  technical  assistance.   The action  items  that  follow
emphasize the need for increased awareness by local officials of their respons-
ibilities for  wastewater utility  management,   the  need to  maintain  effective
local operations and maintenance  management  systems to  keep the plant  in  com-
pliance, and the need to attract, retain, and train operators.

              a. Local Government Management Actions

                 o  Implement a comprehensive (i.e., preventive and corrective)
maintenance management program,  including,  for example,  scheduling,  account-
ability, safety, parts.  Establish a preventive maintenance  budget to maximize
facility life.

                 o  Develop and maintain an effective treatment process manage-
ment control  system and procedures  to  monitor  treatment  operations  and  to
respond to influent,  treatment process, and effluent problems.

                 o  Ensure the community's financial management  capability for
a proposed  facility.   Maintain  financial management  systems to  identify and
recover costs  of operations, maintenance,  management,   equipment  and  facility
repair and replacement,  and  needed operator training.  Update user charge  sys-
tems as needed to fully recover costs.

                 o  Maintain essential inhouse laboratory capability for
process management; maintain or secure certified analytical laboratory capabil-
ity for  permit  reporting.   Submit  accurate and  timely  discharge  monitoring
reports to delegated States or EPA.

                 o  Request that proposed construction plans and specifications
be reviewed  by State  personnel and  local operators for operability  and main-
tainability.

                                      -25-

-------
                  o  Develop awareness of  importance of management of facilities
 to the community and basic understanding of wastewater treatment technologies
 to promote selection of most affordable,  appropriate facility.

                  o  Ensure   the  community  establishes  operator salaries  and
 training opportunities that attract  and retain qualified operators.

               b.  Operator Training-Specific Actions

                  o  Ensure  facilities are staffed by adequate numbers of opera-
 tors and supervisors.

                  o  Ensure  operators and supervisors  are trained  to operate
 facility in compliance with permits, certified at appropriate level, and obtain
 continuing education annually.

                  o  Obtain  private sector, peer,  or State technical assistance
 to  solve operator-related compliance problems.

              c.  Local Government  Implementation Requirements

                  The time frame for achieving effective operations and mainten-
 ance management  and compliance  by local government  will  vary significantly,
 depending on  the  appropriateness of the  current  facility's design,  the under-
 standing by local  government officials  of  their  compliance  responsibilities
 and methods to maintain  compliance, and  competent management  of  the facility
 by  the  community and plant personnel.  Facilities  that are out  of  compliance
 because  of minor  operational  or  financial  problems  can probably  generally
 achieve  compliance  by  the  statutory deadline.  Communities with  major design
 or construction problems, major management problems,  or that  need significant
 new construction will require significant additional time.

            4. Private Sector

              The private sector has always  had  a significant role in publicly
 owned facilities  construction,  operations  and maintenance,  and,  to  a lesser
 extent, operator  training.    This  role is  increasing  and the private  sector
 should continue to represent a  major element in  a  coordinated overall effort.
 Smaller communities  have not been a significant user of private sector training
 and technical assistance services, principally because  of  costs and  geography.
 Nevertheless, the  need  is  apparent  and,  through innovative  approaches,  there
 are additional  opportunities for private-sector training.  The private sector
 could:

              o  Develop independent or State-sponsored multicommunity service
arrangements, including  "circuit-rider"   approaches to  on  site training  and
 technical assistance.

              o  Develop  and market teleconferencing,  "hot-lines",  and micro-
computer  software  programs   for plant  process control,  effluent  control,  and
 financial management. Develop videotape and  self-teaching  materials  for opera-
tor continuing education for inplant or home use.

              o  Develop wastewater  treatment management information materials
and education  programs for  local  elected and appointed officials as well  as
operators.

                                      -26-

-------
              o  Develop information materials and analytical models for munic-
ipal officials to use in evaluating the operational  costs and effectiveness of
their facilities.

     The agency believes that  the  information and proposals  contained  in this
final report establish an effective  foundation for State and  local  action and
fully meet congressional directives to EPA. Following submittal  of this Report
to Congress, the  Report will  be  transmitted to  each State,  various  interest
groups, and professional  associations with  strong  recommendations for  early
action to begin  to  implement these recommendations.  The agency  is committed
to meeting its responsibilities with  States to assure overall municipal facil-
ities compliance  and  to provide policy,  guidance,  oversight,  and  management
assistance for development  of the  compliance-oriented,   self-sufficient  State
and local operator training and operations and maintenance programs.
                                    THE END
                                       -27-

-------

-------
                             HASTEWATER TREATMENT PLANT OPERATOR
                                    STATE TRAINING CENTERS
                                                                             Attachment A
                                                                              Page 1 of 5
Location
New England Regional
Wastewater Institute
South Portland, Maine
NERWI
Southern Maine Technical
  College
2 Fort Road
Portland, Maine 04106

New Hampshire, Concord
Water Supply & Pollution
  Control Commission
P.O. Box 95
Concord, NH 03301

Massachusetts, Boston
Department of Env. Quality
One Winter Street
Boston, MA 02109

Connecticut, Hartford
D.E.P.
State Office Building
Hartford, CT 06106
                                           Region I
New England Regional
Wastewater Institute
Franklin Regional
Treatment Center
                                                            Contact
                                                           Kirk Laflln
                     Phone




                       (207)

                     799-7303
Robert Livingston
(Concord)
(Franklin)
Upper Blackstone District    Marc Perry
Worcester, MA
Connecticut Wastewater
Technology
State Training Center
Bethany, CT

            Region II
Roy Fredricksen
 (603)
271-3503
934-6463
                       (617)
                     292-5698
  (203)
393-2705
New Jersey, New Brunswick
Wastewater Treatment Plant
Dept. of Environmental
  Science, Cook College
Rutgers University
New Brunswick, NJ
New Jersey State Training    Vince Gregorlo
Center
                                          Region III
                       (201)
                     932-9185
Maryland, La Plata
Maryland State Training
Center, Charles County
Community College
Box 910 Mitchell Rd.
La Plata, MS 20646

Virginia, Richmond
J. Sargent Reynolds
  Community College
16SI Parham Road
Richmond, VA  25305
Maryland State Training
Center
Operator Training Center
                                                            Jake Balr
                              Jack Vanderland
                        (301)
                     934-2251
                     ext. 431
                      (804)
                     257-6436
                                                           -28-

-------

-------
                                                                             Attachment A
                                                                              Page 2 of 5
Location

West Virginia, Charleston
Department of Education
1900 Washington St. E.
Charleston, WVA 25305

Washington, D.C.
Depc. of Environmental
  Science
Bur. of Wastewater Treatment
SOOO Overlook Avenue, S.W.
Washington, D.C. 20032
Tennessee, Hurfreesboro
Rte 11 Box 388
Blanton Drive
Murfreesboro, TN 37130

Georgia, Carrollton
Georgia Water and Wastewater
  Institute
P.O. Box 1476
Carrollton, GA 30117
Operator Training Center
(Under Construction)
Cedar Lakes
Department of Environmental
Services
                              Contact
Adam Sponaugle
Charles R. Martin
Phone

  (304)
 348-3075
  (202)
 727-5757
                                               Resign IV
Murfreesboro State
Training Center
Georgia Water and
Wastewater Institute
Jack Hughes
Jim Bennett
  (615)
 890-7008
  (404)
 834-1468
Florida, Gainesville
The U. of Florida
TREEO Center
3900 S.W. 63 rd Blvd.
Gainesville, FL 32608

South Carolina, Sumter
Sunter Area Technical
  College
506 N. Guignard Drive
Sumter, SC 29150
Ohio, Columbus
State Training
Operator Training Committee
  of Ohio Inc.
3972 Indianola Avenue
Columbus, OH 43214

Illinois, Edwardsville
Environmental Resources
  Training Center
Southern Illinois U.
P.O. Box 75
Eduardsville, IL 62026
                              TREEO Center
South Carolina Water
Quality Institute
  Region V

Ohio State Training
Center
Environmental Resources
Training
                             Dr. Barbara Mitchell (904)
                                                  392-2464
Dr. William Engle    (803)
                    778-1961
Richard F. Mellet    (614)
                    846-2812
TOD Woocers
  (217)
 692-2030
                                                           -29-

-------
                                                                             Attachment A
                                                                              Page 3 of 5
Location
    Name
                                                             Contact
                    Phone
Arkansas, Camden
Southern Arkansas University
  Technical Branch
P.O. Box 3048
East Camden, AK 71701
          Region VI

Southern Arkansas
Environmental Academy
Richard VanPelt
 (501)
574-4550
New Mexico, LaaCruces
Dona Ana County
Occupational Education
  Branch, Hew Mexico
  State University
P.O. Box 3 DA
LasCruces, HM 88003

Oklahoma, Midwest City
Rose State College
6420 Southeast 15th Street
Midwest City, OK 73110
Iowa, Cedar Rapids
Hastewater Treatment Plant
  Operator
Training Center
Kirkwood Community College
P.O. Box 2068
Cedar Rapids, IA 52406

Kansas, Topeka
State Technical Training
Kansas State Department of
  Health and Environment
Topeka, KS 66620

Missouri, Neosho
Missouri Water and
  Wastewater Operator
Training Facility
Crowder Community College
Neosho, MO 64850
Hater Utilities Technology
Program
Eugene E. Nelms      (505)
                    646-2730
Hater Utilities Training
Center
                                               Region VII
Dr. William Roach     (405)
                    733-7364
Waste & Wastewater
Technology Center
Doug Fell
 (319)
393-5677
 Fort Scott Community Coll.
 Salina Community College
 Dodge City Community Coll.
 Missouri Operator Training
 Center
                                              Region VIII
Karl Mueldener
                              Richard Thexton
 (913)
862-9360
                     (417)
                    451-3583
Colorado, Denver
Community College of Denver
Red Rock Campus
1600 Downing Street
Denver, CO  80218
Colorado Wastewater           Tom Feeley
Operator Training Center
                      (303)
                    988-6160
                    ext. 334
                                                           -30-

-------
Location

Utah, Provo
Utah Technical College
1395 N. ISO East
P.O. Box 1609
Provo, tJT 84603

Wyoming, Casper
Casper College
125 College Drive
Casper, WY 82601
    Ha»e

Wastewater Operator
Training Facility
Casper College
State Wastewater
Training Center
                                                           Contact
Debra Korton
Gale Zimmerman
Bill Mixer
                                                                            Attachment  A
                                                                             Page 4  of  5
Phone

 (801)
226-5000
  (307)
268-2542
268-2670
                                              Region IX
California, San Marcos
California State CSWRCB
Hater Quality Institute
810 W. Vallecitos Street
Suite A
San Marcos, CA 92069

Government of Guam
P.O. Box 23609
Agana, Guam

Commonwealth of the
  Marianas, SAIPAN
Trust Territory of the
  Pacific Islands
SAIPAN, CM 96950

Arizona, Tucson
Plma County Coam. College
8202 East Poinciana Drive
Tucson, A2 85730
Washington, Auburn
Washington State Water/
  Wastewater Training Center
Green River Community College
12401 SE 320th Street
Auburn, WA 98002

Idaho, Boise
Boise State University
School of Vocational
  Education
2221 N.W. 8th Street
Meridian, ID 83642
CSWRCB Water Quality
Quality Institute
Guam Community College
Office of Planning and
Statistics
Arizona Wastewater
Operator Training
Center

         Region X

Waste Training Program
Michael Poplchak      (619)
                    744-4150
                              Stan Malkln
                     <617)
                    734-4311
Charles D. Jordan    SAIPAN
                     9333
David Landsburg      (602)
                    886-3812
                                                           Fred Delvecchio
Wastewater Training Center    Veronica  Fitz
                     (206)
                    833-91U
                    ext.  369
                    (208)
                    382-3735
                                                         -31-
                                                    U.S. EPA Headquarters Library
                                                           Mail code 3201
                                                   1200 Pennsylvania Avenue NW
                                                       Washington DC 20460

-------
                                                         Attachment A
                                                         Page  5  of 5
     State Training Centers Being Considered
Puerto Rico
Alabama
Louisiana
Nebraska
Montana
Hawaii
Alaska
Oregon
                                     -32-

-------
Region I
COMPLIANCE STATUS OF INDIVIDUAL PLANTS
         82/83 FUNDING
                                                                                ATTACHMENT B
                                                                                PAGE 1  OF 20
STATE
*
Connecti-
cut










Maine


Massachu-
setts




New
Hanpshire














Rhode
Island
Vermont





NAME OF CCtMDNITY

Bethel
Branford
Bridgeport East
Bridgeport West
Bristol Forrestville
Bristol Main
Manchester
New Hartford
North Haven
Seymour
Stoning ton Borough
West Haven
Brewer
Lisbon
Paris Utility District
Attleboro
Edgartown
Holyoke
Merrimack
North Attleboro
Somerset
Ashland
Concord (Penacook)
Derry
Franklin
Hampton
Lisbon
Milford
Newfields
Sollinsford
Salem
Strafford Co. Hone
Sullivan Co. Hone
Sunapee
Trey
West Swanzey
Woodsville
Smithfield

Chester
Lydonville
Pittsford
Richmond
West Ruthland
Woodstock
SIZE
(MGD)

1.0
4.5
12.0
30.0
5.0
3.5
6.7
0.07
4.6
1.0
0.67
12.7
3.0
1.5
1.85
8.6
0.35
7.5
0.45
4.6
1.6
1.6
10.1
0.75
11.5
4.7
0.37
2.15
0.12
0.15
1.3
0.05
0.05
0.64
0.26
0.16
0.33
3.5

0.18
0.75
0.07
0.22
0.325
0.24
TYPE

AS
AS
AS
AS
TF
TF
EA
EA
TF
AS
AS
AS
AS
AS
AS
2Stage
EA
AS
CO
AS
EA
AL
AS
AL
AS
AS
SP
EA
AL
OD
TF
AL
AL
OD
AL
AL
EA
AS

EA
EA
EA
EA
EA
EA
IN
COMPLIANCE


X
X
X
X
X



X
X

X


X
X

X
X
X
X
X
X
X
X
X
X


X




X
X


X
X

X
X

IMPROVED
PERFORMANCE

X





X
X
X


X

X
X


X










X
X

X
X
X
X


X



X


X
NO
CHANGE!














































STILL IN
TRAINING

X
X
X
X
X
X
X
X
X
X
X
X
X
X
X








X


X

X
X
X
X
X
X
X


X

X
X
X
X
X
X
                                                             -33-

-------
Region I
COMPLIANCE STATUS OF INDIVIDUM, PLANTS
         82/83 FUNDING
                                                                                ATEftCHMENT B
                                                                                PAGE  2 OF 20
STATE
NEIWPCC




















NAME OF COMMUNITY
Fort Kent
Limestone
Blue Hill
Bar Harbor
Orono
Lewiston-Aufaum
Anesbury
Manchester
South Bridge
Ipswich
Erving-flillers Palls
Saxton's River
Wallingford
White Rider Jet.
(Hartford)
Poult-Tey
Brandon
Castleton
Fair Haven
Orleans
Barton
SIZE
(MGD)
0.7
0.162
0.07
1.4
1.64
14.2
1.9
0.67
2.3
1.8
1.0
0.1
0.12

0.97
0.35
0.7
0.36
0.2
0.19
0.26
TYPE
OD
AS
EA
AS
AS
AS
EA
EA
EA
EA
AS
00
OD

EA
EA
OD
EA
OD
AL
AL
IN
CXHPUANCE
X
X
X
X
X
X
X
X
X
X
X
X


*"

X
X
X
X
X
IMPROVED
PERFORMANCE












X

X
X





NO
CHANGE





















STILL IN
TRAINING
X
X
X
X
X
X
X
X
X
X
X
X
X

X
X
X
X
X
X

                                                           -34-

-------
                                                                                 ATTACHMENT B
                                                                                 PAGE 3  OF 20
"Region II
COMPLIANCE STATUS Of INDIVIDUAL PLANTS
         82/83 FUNDING
STATE
*
New
Jersey








New York













Puerto
Rico








-
NAME OF COMMUNITY
Aberdeen
Harrington
Bell Manor
Bryan TWP Int. SC.
East Windsor
Florence
Glouoester-Bloclcwood
Hamilton
Paljnayra
Pennsauken
Brownville
Buchanan
Canden
Clayton
Cableskill
Deferiet
Dekalb
Delhi
Pulton (City)
Livingston Manor
Lloyd
Potsdam
Rose.Tdale
Walton

Bayanon Covadonga
Bayamon Gardens
Bayamon-Las Teresasas
Bayamon-Royal Town
GUrabo
Hamacao
Loiza Valley Canovanas
Naran j ito
8io Grande
Truijillo Alto
	 	
SIZE
(MGD)
0.8
1.2
1.8
0.018
2.23
1.5
.625
6.75
0.5
4.0
0.65
0.55
0.80
0.30
0.75
0.08
0.03
0.575
3.30
0.80
1.25
3.30
0.10
1.17

1.0
0.670
0.375
2.062
0.60
0.25
0.513
0.5
0.375
0.50
TYPE
AS
AS
AS

AS
TF
AS
TF
TF
TF
AS
AS
OD
TF
AS
AS
AS
TF
TF
AS
RBD
AS
AS
TF

AS
TS
CG
TS
AS
AS
CG
AS
CS
CS
IN
COMPLIANCE
X


X



X







X
X




X



X









IMPROVED
PERFORMANCE





X



X

























NO
CHANGE

X
X

X

X

X

















X
X
X
X
X
X
X
X
X
STILL IN
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
V
X
X
X
X
X
X
X
X

X
X
X
X
X
X
X
X
X
X
                                                               •-35-

-------
                                                                               ATTACHMENT B
                                                                               PAGE 4  OF 20
Region III
COMPLIANCE STATUS OF INDIVIDUAL PLWIS
         82/83 FUNDING
STA1E
Delaware







Maryland











Pennsyl-
vania








Virginia










Nest
Virginia



NAME OF COMMUNITY
Bridgeville
De Seashore Park
Harrington
Laurel
Lewes
Milton
nfinoboul
Selfayville
Accident
Betterton
Broadneck
Centreville
Friendville
U^vwiAl?
HAIiOOCK
Millington
Oxford
Princess Anne
Queenstown
Ridgely
Snow Hill
Adamstown
Alexandria
Clarks Sumnit
Greenfield Township
Lynn Township
Media Borough
Nilleville
Mt. Pocono
Saxonburg Borough
Sunbury
Colonial Beach

Kilraamack
Mathews
Middleburg
Plains Marshall
Purcellville
Reedville
South Boston
anithfield
West Point
Alderson
Beverly
Bruce ton/Brandonv i 1 le
Buffalo
Cheylan
SIZE
(MGD)
.08
.13
.75
.75
.75
.25
.3
.70
.075
.2
4.2
.375
.1
.2
.07
.125
.7
.2
.2
.5
0.30
0.12
1.20
.25
0.08
1.80
0.14
0.40
0.50
3.50
0.80

0.20
0.10
-
0.16
0.50
0.20
2.0
0.5
0.30
.4
.34
.06
.75
.3
TYPE
TF


L



L
AS
EA
AS
TF
AS
L
CS
L
TF
TF
AS
RBC
CS
CS
EA
CS
EA
TF
CS
CS
EA
AS
Packed
Tower
EA
CS
RBC
EA
EA
EA
AS
OD
TF
AS
AS
TF
AS
AS
IN
COMPLIANCE








X
X
X
X
X

X
X
X


X

X
X



X
X


















IMPROVED
PERFORMANCE


















X

X



X
X


X

















NO
CHANGE













X



X





X
X





X

X
X
X
X
X
X
X
X
X





STILL IN
TRAINING
X
X
X
X
X
X
X
X





X



X
X




X
X





X

X
X
X
X
X
X
X
X
X
X
X
X
X
X
                                                             -36-

-------
                                COMPLIANCE STATUS OF INDIVIDUAL PLANTS
Region III                               82/83 FUNDING
       •Training provided by National Demonstration Vfater Project (NDMP)
                                                                                ATTACHMENT B
                                                                                PAS:  5  OF 20
STATE











































w



NAME OF COMMUNITY
Colfax
Culloden
Delbacton
Glen Rogers
Romnex
Roncervete
New Haven
Shepherds Town
St. Marys
Wardensville
Wellsburg
Bradlex
Huttonsville
Jane Lew
Arbuckle
•Ansted
•Beliagton
•Belmont
•Cairo
•Cameron
*Davis
•Elizabeth
*Elkins
* E 1 lenboro-Larabe rton
•Farmington
•Follansbee
•Gle.iville
•Grantsville
•Harrisville
*Hcx3versan Heights
•Junior
•Maiden
•Mannington
•Middleboume
•Monogah
•New Mart insvi lie
•Rivesville
•Rowlesburg
•Rupert
•Spencer
•Suntnersville
•Thonas
•Tunnel ton
•Weirton
*Wellsburg
•West Hand in
•Williamstown
SIZE
(MGD)
.08
.2
.25
.1
.4
.32
.22
.4
.3
.11
1.2S
.4
.25
.15
.35
































TYPE
AS
AS
TF
AS
AS
AS
AS
AS
AS
AS
AS
AS
AS
AS
AS
































IN
COMPLIANCE















X

X


X

X


X
X
X

X
X




X

X
X
X



X
X
X

IMPROVED
PERFORMANCE
















X




X









X








X
X
X




NO
CHANGE


















X
X



X
X



X



X
X
X

X









X
STILL IN
TRAINING
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X



X
X



X
X



X



X
X
X

X









X
                                                           -37-

-------
                                                                                ATTACHMENT B
                                                                                PAGE 6  OF 20
Region IV
COMPLIANCE STATUS OF INDIVIDUAL PLANTS
         82/83 FUNDING
STATE
Florida









Georgia













North
Carolina








South
Carolina













NAME OF COMMUNITY
Belleaire
Deland
Ft. Walton Beach
Iimekalee
Kisairaonee
New Symrna Beach
Nioeville
Pahokee
Scoring
Sneads
Andersonville
Baconton
Bowdon
Braner
Buchanan
Clarksville
Cleveland
Conroerce
Franklin
Ft. Gaines
Glennville
GzBenboro
Haipton
Plains
Beaulaville
Boonville
Dunn
Farmville
Hsnlet
Highlands
Kenansville
ftobbinsville
Jtobersonville
Swansboro
Barnwell
Batesburg
Cayce
Edgefield
Johnston #1
Johnston #2
Land O Lakes
Manning
N. Augusta
Newberry #1
Newberry *2
Prosperity, E. Lagoon
Prosperity, W. Lagoon
Ridgeway
SIZE
(MGD)
0.9
8.0
4.5
5.0
3.0
4.0
2.0
1.2
2.0















.26
0.1
2.275
3.5
1.0
0.246
0.17
0.13
1.2
0.3
1.0
1.3
4.0
0.61
0.66
0.12
.003
1.0
0.05
0.500
0.015
TYPE
AS
EA
RBC
CD
AS
AS
CS
AS
AS

EA
EA







EA




AL
EA
EA
EA
EA
EA
OD
EA
EA
OD
TF
EA
EA
00
TF
OD
CS
AS
EA
L
CS
0.800) AL
0.015
0.120
AL
EA
Wade Hampton 4.00 AS
IN
COMPLIANCE
X
X
X
X

X
X

X
X



X
X
X
X
X



X




X

X
X






X



X
X

X



X

IMPROVED
PERFORMANCE







X
















X
X




X
X


X


X
X
X




X



X
NO
CHANCE




X






























X






X






Willliston .800J AL X
STILL IN
TRAINING










X
X






X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X

X



X
X
                                                            -38-

-------
                                           ATTACHMENT B
                                           PAGE 7  OF 20
COMPLIANCE STATUS OF INDIVIDUAL PLANTS
        82/83 FUNDING
STATE
Sooth
Carolina
































Tennesee









"



•


NAME OF COMMUNITY
•Aiken
*Batesburg
"Bennettsville
•Berkeley
•Cayce
*Chester-Sandy River
•Chester-Rocky Creek
•Clemson
•Clover
•Dillon
•Florence
•Gaffney-Clary
•Gaffney-Providence Creek
•Hardeeville
•Hartsville
*Irnan Mills
•Jefferson
•Kershaw
•Kingstree
•Lake City
•Manning
•Marion
•McCormick
•Ninety-Six
•Ridgeland
•Riverdale Mills
•Saluda
•Suimerton
•Vfalterboro
"VCRSA Travelers Rest
•WCRSA Parker
•WCRSA Lakeside
•Vihitmire
•Winnsboro
Alexandira
Bell Buckle
Copper Hill
Decatur
Dyer
Fayetteville
Friendship
Huntsville
Jellico
New Bern
Old Hickory
Oliver Springs
Rockwood
Rutledge
Sharon (enforcettent act)
Signal Mountain
•Caryv i 1 le-Jacksboro
•Crossville
SIZE
(MGD)


































.15
0.150
.4
.17
.675
2.66
.093
.08
.4
.4
1.0
1.0
1.65
.16
.15
.4

TYPE


































CS
GA
OD
EA
OD
CAS
OD
CS
AS
TF
TF
CS
TF
EA
EA
AS

IN
COMPLIANCE

X


X
X
X

X


X
X
X

X

X
X
X


X
X


X
X



X

X
X
X
X
X
X
X
X

X


X

X

X
X
IMPROVED
PERFORMANCE
X








X
X









X
X


X
X



X
X

X










X
X



X


NO
CHANGE


X
X



X






X













X












X




X


X

STILL IN
TRAINING


X
X



X






X













X






X



X

X
X
X
X

X

X
X
X

                           -39-
U.S. EPA Headquarters Library
       Mail code 3201
1200 Pennsylvania Avenue NW
   Washington DC 20460

-------
                                                                                  ATTACHMENT B
                                                                                  PAGE 8  OF 20
Region IV
 Training provided by NDMP
COMPLIANCE STATUS OF INDIVIDUAL PLANTS
         82/83 FUNDING
          •Dayton
          •Forks of the River
          *»2 Knox Utility District
          •Oliver Springs
          •cneida
          •Pikeville
          •Sevierville
          •faring City
          •Sweetwater
          •Tellico Plains
          •Whitwell

          •Albany
          •Beattyville
          •Benham
          •Bledsoe
          •Caney Creek
          •David
          •Elkhom City
           Evarts
          •Fleming-Neon
          *Harlan
          •Hazard
          •Hindjnan
          •Hyden
           'Jackson
          •Livingston
           London
          •Loyall
          •Martin
          •Pikeville
          •Salyersville
          •Wheelwright
          •Vihiteburg
                       X
                       X
                       X
                       X
                       X
                       X
                       X
                       X
                       X
                       X
                       X
                       X
                       X
                       X
                       X
                                   X

                                   X
                                   X
                                   X
                                   X
                                   X
                                   X
                                             X
                                             X
X
X
X
X
X
                                                       X
                                                       X
                                                       X

                                                       X
                                                               -40-

-------
legion IV
Training provided by NDHP
COMPLIANCE STATUS OF INDIVIDUAL PLANTS
         82/83 FUNDING
                                                                                ATTACHMENT B
                                                                                PAGE 9  OF 20
STATE
m
lississ-
.ppi

































-
NAME OF COMfJNm
•Batesville
*Belzoni
*Bolton
*Burnsville
•Gary
•Charleston
•Cleary Heights
•Coahcma Jr. College
•Coffeeville
•Crosby
•Delta City
•Falcon
•Forest
•Glendora
•Gloster
•Guntown
•Hickory
•Hollandale
•Inverness
•Lexington
•Long Beach
•Mantachie
•Marietta
•Meadville
•Mound Bayou
•Pass Christian
•Picayune
•Reinzi
•Rosedale
•Shubuta
•anithville
•Tchula
•Union
•Have land
•West
•Wbodville
SIZE




































TYPE




































IN
COMPLIANCE




X
X




X
X





X
X

X

X


X
X

X



X
X

X
IMPROVED
PERFORMANCE


X
X


X
X
X
X


X
X

X
X


X



X
X


X

X
X
X




HO
CHANGE
X
X












X .






X












X

STILL IN
TRAINING


































X

                                                              -41-

-------
                                                                                ATTACHMENT B
                                                                                PAGE 10 OF 20
Region V
COMPLIANCE STATUS OF INDIVIDUAL PLANTS
         82/63 FUNDING
STATE
Illinois






Indiana










Michigan









Minnesota









Ohio







NAME OP COMMUNITY
Ashton
Byron
Hardin
Orion
Riverton
Elizabeth
Wiite Hall
Osgood
North Vernon
Eaton
Goshen
Knox
Lapel
Middlebury
Westville
New Carlysle
North Salem
Whitestown
Bessemer
Ourand
Evart
Harbor Beach
Manistee
Milford
Newberry
Owosso
Paw Paw Lake, Colona
Lowell
Barnum
Brownton
Clarissa
Cemfrey
Editions
Grand Mara is
Le Center
Mable
Sandstone
Staples
Hellesville
Carrollton
Mahoning-Meader Creek
Hahoning-Boardman
Southpoint
Gnadenhutten
Plesant Valley RD6
Eldorado
SIZE

-------
                                                                                ATTACHMENT B
                                                                                PACE 11 OF 20
Region V
COMPLIANCE STATUS OF INDIVIDUAL PLANTS
         82/83 FUNDING
STATE
Wisconsin











NAME OP COMMUNITY
Hllbert
Marathon City
Heyerhauser
Clinton
Mount Horeb
Waldo
Galesville
Pli» City
DOT Rest Stops 26, 36
Iron Belt
Central Wisconsin Airport
Coleman
SIZE
(MGD)
.171
.3
.04
.305
.79
.2
.31
0.06
.009
.032
.025

TWE
AL
AS
SP
TP
RBC
AS
TP
AS
SP
SB
EA

IN
COMPLIANCE

X
X

X
K

X

X


IMPROVED
PERFORMANCE
X


X


X

X

X

NO
CHANGE












STILL IN
TRAINING
X
X
X
X
X
X
X
X
X
X
X
X
                                                              -43-

-------
                                                                                ATTAOWENT B
                                                                                PAGE 12 Of 20
Region VI
   •Training provided by NTHP
COMPLIANCE STATUS OF INDIVIDUAL PLANTS
         82/83 FUNDING
STATE
Louisiana















New
Mexico




Arkansas











Texas






Oklahoma








NAME OF COMMUNITY
Abita Springs/Lynn -
Bridges
Basile
Blanchard
East Hodge
George torn
Lake Authur
Merryville
Pleasant Hill
•Delhi
*Gilbert
'Livingston
Loureauville
•Madisonville
•Port Barre
•Walker
Ruidoso
Cloudcroft
Aztec
Reserve
James Brings
Eunice
Brook land
Calvin
Dardanelle
Greenbrier
Huntington
Madison
Magazine
Pangbum
Paris
Prescott
Stanpo
Taylor
Deavers
Harris County FWSDi 6
Kings land MUD
Lake LBJ MUD
Orchard
Shape rd
W. Tawakoni
Broken Bow
Checotah
Eufaula
Hartshorn
Kingston
Lexington
Stringtown
Yale
Grove
SIZE
(MGD)

.12
.45
.19
.06
.6
.75
.25
.10







2.6
1.0
1.5
.075
.045
.3
.12
.12
1.0
.2
.1
.3
.15
.1
.75
1.0
.6
.12
.08
.2


.04
.165
.3
.30
.4
.3
.25
.3
.2
.15
.2
.042
TYPE

OD
00
OD
EA
EA
TF
OD
OD







EA
TF
EA
EA
EA
TF
SP
AL
AS
AL
OD
AS
AS
SP
OD
AS
AS
AS
AS
AS


CS
CS
EA
AS
OD
OD
OD
AS
AS
AS
AS
FA
IN
COMPLIANCE


X
X

X
X
X
X




X

X
X
X
X
X
X

X
X

X
X

X

X
X
X
X







X
X
X
X
X
X
X
X
y
IMPROVED
PERFORMANCE

X


X




X
X
X









X


X


X

X




















NO
CHANGE












X

X



































STILL IN
TRAINING

X
X
X
X
X
X
X
X
X
X
X
X

X




X
X
X
X

X


X

X


X

X
X
X
X
X
X
X









                                                            -44-

-------
                                                                                 ATTACHMENT B
                                                                                 PAGE 13 OF 20
Region VI
COMPLIANCE STATUS OF INDIVIDUAL PLANTS
         82/83 FUNDING
STATE
-

















NAME OF COWWNinf
Bristol*
Pittsburs
Ardcraore
Braggs
Broken Arrow
Henryetta
Miami
Okay
Porter
Vinita
Wagoner
Locust Grove
Beggs
Jay
Tecunseh
Choceteau
Sali.na
Carney
SIZE
(MGD)
.4
.05
1.0
.022
.225
.3
.048
.016
.02
.048
.042
.022
.033
.092
.075
.042
.04
.02
TYPE
EA
AS
EA
OD
EA
EA
EA
EA
OD
OD
EA
TF
EA
EA
EA
TF
L
AL
IN
COMPLIANCE
X
X
X
X
X
X
X
X
X
X
X







IMPROVED
PERFORMANCE


















NO
CHANGE


















STILL IN
TRAINING

X
X
X
X
X
X




X
X
X
X
X
X
X

-------
                                                                                ATTACHMENT B
                                                                                PAGE 14 OP 20
Region VII
COMPLIANCE STATUS OF INDIVIDUAL PLANTS
         82/83 FUNDING
STATE
Missouri



































Nebraska












NAME OP OMKJNm
Alba
Atlanta
Bolivar
Bourbon
Buffalo
Butler
Cassville
Charleston
Crane
Cuba
Edina
Farming ton
Harrisonville
Homestead Village
Kearay
Licking
Louisiana
Haoon
Moberly
Miangya
Mount Vernon
Newburg
Noel
Osoeola
Pevley
Pineville
Platte City
Seed Springs
Rhoch Port
Seymour
Shelbina
Slater
St. James
Tipton
Van Buren
waverly
Brownville
Cambridge
Coleridge
Crawford
Crofton
Egkhorn
Geneva
Hebron
Laurel
Murray
Pilger
Riverside Lakes
Spencer
SIZE
(MGD)
.07
.05
.40
.10
.35
.70
1.25
.6
.07
.3
.5
1.075
1.0
.03
.15
.64
.75
2.1
1.6
.035
1.0
.75
.50
.06
1.5
.075
.80
.03
.25
.225
1.25
.40
.46
.435
.40
.12
.015
.257
.075
.150
.100
.28
.322
.217
.142
.05
.045
.060
.056
TYPE
OD
TF
OD
OD
OD
OD
OD
TF
TF
CS
OD
TF
CS
EA
CS
CS
CS
TF
TF
OD
TF
CS
OD
CS
AS
CS
EA
CS
OD
CS
EA
OD
OD
OD
OD
OD
AS
OD
AS
TF
OD
AS
RBC
OD
OD
RBC
AS
AS
AS
IN
COMPLIANCE
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X




X

X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X

X
X

IMPROVED
PERFORMANCE













































X



NO
CHANGE























X
X
X
X

X



















X
STILL IN
TRAINING



X
X









X

X


'

X

X
X


X
X


X


X
X









X


X
                                                           -46-

-------
                                                                                ATTACHMENT B
                                                                                PAGE 15 OP 20
Region VII
COMPLIANCE STATUS OF INDIVIDUAL PLANTS
         82/83 FUNDING
STATE
"





Iowa




































•




NAME OF COMMUNITY
WahOO
West Point
Winser
Weeping Watyer
Wood River
Yutan
Adair
Akron
Bloomfield
Cascade
Central City
Dayton
Denson
Dewitt
Eldora
GturxJy Center
Hills
Hundsoo
Janes vi lie
Jefferson
Keystone
Lake Mills
Logan
Manchester
Maquoketa
Maxwell
Milford
North English
Orange City
Readlyn
Red Oak
Rock Rapids
Rockwell City
Runnel Is
sibley
Solon
Steamtoar Rock
Stratford
Swisher
Vinton
Kaukon
Webester City
West Liberty
west Union
Whihemore
Wi Hams burg
Winfield
Winterset
SIZE
(MOD)
.69
.575
.160
.148
.200
.120
.10
.967
1.14
.250
.187
.090
2.73
.520
1.0
.832
.037
.50
.165
1.1 1
.07
.360
.20
.823
2.5
.108
2.6
.075
.2
.1
.796
.384
.288
.070
.670
.400
.049
.071
.09
1.8
.89
2.3
1.37
.435
.147
2.1
.239
1.25
TYPE
AS
AS
AS
AS
RBC
RBC
TF
CS
TF
RBC
TF
TF
EA
TF
SBR
SBR
EA
EA
EA
EA
SP
TF
CS
EA
RBC
TF
RBC
TF
TF
EA
TF
TF
TF
EA
EA
EA
TF
EA
EA
EA
TF
RBC
CAS
TF
TF
EA
TF
TF
IN
COMPLIANCE
X
X
X
X

X
X

X
X
X





X
X
X



X

X

X
X





X
X
X

X
X

X
X



X


IMPROVED
PERFORMANCE




X


X



X
X
X
X
X




X
X

X




X
X






X


X



X
X

X

NO
CHANGE



















X





X




X
X
X









X




X
STILL IN
TRAINING




X


X
X



X

X
X



X

X

X

X


X
X









X



X
X

X
X
                                                              -47-

-------
                                                                                ATTACHMENT B
                                                                                PAGE 16 OP 20
Region VII
COMPLIANCE STATUS OF INDIVIDUAL PLANTS
         82/83 FUNDING
STATE
Kansas




























NAME OF COMMUNITY
Atchison
Belleville
Bennington
Blue Mound
Buffalo
Crinarron
Colony
Deerfield
Douglass
Ellinwood
Frontenac
Goodland
Handover
Hiawatha
Holton
Hoxie
lola
LaHarpe
Lamed
Lincoln
Madison
Medicine Lodge
Mulvane
Oakley
Osage City
Prescott
St. George
Wilson
Yates center
SIZE
(MQJ)
2.8
.461
.1
.0372
.04
.216
.490
0.7
.22
—
-
-
.1
1.10
.336
.2
1.62
.135
.65
.37
.15
-
.4
-
.4
.03
.045
1.0
.3
TYPE
AS
RBC
AS
AS
AS
TF
AS
AS
AL
TF
CS
AS
AS
TF
RBC
TF
AL
AS
TF
RBC
AS
TF
RBC
TF
AS
AS
EA
TF
AS
IN
COMPLIANCE
X
X
X
X
X
X

X
X
X

X
X
X
X
X
X
X
X
X
X
X

X

X
X
X
X
IMPROVED
PERFORMANCE






X















X






NO
CHANGE





X




X













X




STILL IN
TRAINING

X



X
X



X









X

X

X




                                                             _48-

-------
                                                                               ATTAOWENT B
                                                                               PAGE 17 OF 20
Region VIII
COMPLIANCE STATUS OF INDIVIDUAL PLANTS
         82/83 FUNDING
STATE
Colorado







Montana



>lorth
Dakota



























.




,

NAME OF COMMUNITY
Glenwood Springs
W. Glenwood Springs
Rifle
Silt
Carbondale
Brighton
Ft. Morgan
New Castle
Forsyth
Kalispell
Livingston
Missoula
Washburn
Steele
Tappen
Streeter
Linton
Hazen
Bowman
Abercrambie
Christine
Dwight
Zap
New Leipzig
Garrison
Par shall
Wilton
Dodge
Regent
Golva
Medora
Richardton
Taylor
Hoople
Crystal
Edinburg
Fordville
Mountain
Glenbum
Flasher
Kulm
Crosby
Noonan
Ray
Forbes
La Moure
Williston
Portal
SIZE
(MGD)









2.7
2.0
10.0
SD
SD
SD
SD
SD
SD
SD
SD
SD
SD
SD
SD
SD
SD
SD
SD
SD
SD
SD
SD
SD
SD
SD
SD
SD
SD
SD
SD
SD
SD
SD
SD
SD
SD
SD
SD
TYPE
RBC
AS
Lagoon
Lagoon
AS
TF
Lagoon

SP
SP
RBC
SP
SP
SP
SP
SP
SP
SP
SP
SP
SP
SP
SP
SP
SP
SP
SP
SP
SP
SP
SP
SP

SP
SP
SP
SP
SP
SP
SP
SP
SP
SP
SP
SP
SP
SP
SP
IN
COMPLIANCE
X
X
X
x
X


X
X

X
X




































IMPROVED
PERFORMANCE









X


X



















X















NO
CHANGE





X
X









































STILL IN
TRAINING





X
X









































                                                              -49-

-------
ATTACHMENT B
COMPLIANCE STATUS OF INDIVIDUAL PLANTS PAGE 18 OF 20
Region VIII 82/83 FUNDING
STATE
North
Dakota
















NAME OF COMMUNITY
Columbus
Powers Lake
Haddock
Hinnewaukan
Uphan
Munich
Towner
Horace
Butte
Dunn Center
Ashley
Berthold
Courtenay
Bowdon
Dazey
Alexander
Bowbells
Forbes
SIZE
(MGD)
SD
SD
SD
SD
SD
SD
SD
SD
SD
SD
SD
SD
SD
SD
SD
SD
SD
SD
LaMoure SD

South
Williston Portal SD
Bryant SD
Dakota jChanberlain
JGuster State Hospital
(Custer State Park





Game Lodge SD
TYPE
SP
SP
SP
SP
SP
SP
SP
SP
SP
IN
COMPLIANCE









SP
SP
SP
SP
SP
SP
SP
SP
SP
SP
SP
SP
OD

AS
SP
Sylvan Lake SD SP
Legion Lake SD SP
Blue Bell SD SP
Elkton SD SP
|Ft. Pierre SD SP
| Iroquois SD SP



Utah




Wycming




Newell
Pierre
Salem
Tooele
Silina
Payscn
Cedar City
Sandy
SD SP
RBC
SD
1.5
.45
1.25
2.25
1.5
Aspen .1
South Cheyenne .8
Midwest .04
SP
TF
TF
TF
TF
AS
AS
AS
AS
Hulett .04 AS
Gillette 1.2
JThennopolis
0.6
AS
TF




















X
X











IMPROVED
PERFORMANCE







































X

NO
CHANGE









































STILL IN
TRAINING




















X
X
X























-50-

-------
                                                                         ATTACHMENT B
                                                                         PAGE 19 OF 20
•Region IX
COMPLIANCE STATUS OF INDIVIDUAL PLANTS
        82/83 FUNDING
STATE
*
Califor-
nia



Hawaii

*
NAME OF COMMUNITY
Mamroth Co Water District
Bass Lake
City Bishop
City of Ridgecrest
Carmelle
Hilton Creek
Blithe
Kailua Ke.ia
Kulaiman

SIZE
(HGD)
3.0
.5
.9
2.9
2.3
.05
1.4
1.0
0.5

TYPE
AS
CS
PT
PT
AS
AS
TF
AS
AS

IN
COMPLIANCE

X
X

X
X


IMPROVED
PERFORMANCE


X
X
X




NO
CHANGE
X





X

STILL IN
TRAINING
X

X
X
X




                                                      -51-
                                                                            U.S. EPA Headquarters Library
                                                                                   Mail code 3201
                                                                            1200 Pennsylvania Avenue NW
                                                                               Washington DC 20460

-------
                                                                                 ATTACHMENT B
                                                                                 PA5E 20 OF 20
Region X
COMPLIANCE STATUS OF INDIVIDUAL PLANTS
         82/83 FUNDING
STATE
Alaska





Idaho






Oregon




Washing-
ton






NAME OF COMMUNITY
Eagle River
Nenana
KalMOck
Mountain Village
Fairbanks
Haines
Hailey
Ketchun
Harriaon
Grace
Priest River
Stites
Juliaetta
Pacific City
Dallas
Estacada
Cascade Locks
Nyssa
Brewster
Crystal Mountain
Cusick
Elma
Leavenworth
Tekoa
Tulalip
Vashon Sewer District
SIZE
(MO))
2.0
0.8
0.2
0.1
4.5
.250




















TYPE
RBC



AS
AS


AL
OD
OD
L

AS
AS

EA

EA/OD



EA/OD



IN
CCMPLIANCE






X






X
X











IMPROVED
PERFORMANCE
X














X










NO
CHANGE




X











X









STILL IN
TRAINING
X
X
X
X
X
X
X
X
X
X
X
X
X



X

X
X
X
X
X
X
X
X
              Type of Plant
                TF  -  Trickling Filter
                AS  -  Activated Sludge
                CS  -  Contact Stabilization
                CG  -  Clarigestor
                R8C -  Rotating Biological Contactor
                SP  -  Stabilization Pond
                AL  -  Aerated Lagoon
                L   -  Lagoon
                PC  -  Physical-Chemical; Carbon Absorption
                EA  -  Extended Aeration
                OD  -  Oxidation Ditch

              Size of Plant
                SD  -  Seasonal Discharge
                                                               -52-

-------
                         STATUS OF STATE ONSITE OPERATOR TRAINING
              AND TECHNICAL ASSISTANCE PROJECTS FUNDED IN PY 1982 AND FY 1983
*Training provided  by NDWP
                                                                             ATTACHMENT C
                                                                             Page 1  of  3
STATE
«
Region I

Ventont
New Hampshire
Ma ssachuse tts
Connecticut

Rhode Island
NEIWPC

Maine
Region II

New Jersey
82/83
ALLOCA-
TION


* PLANTS IN
STATE UNDER
5 MGD BUILT
W/FEDERAL $


$ 50, 000 | 82
|
126,000) 65
i
50, 000 | 96
i
90, 000 | 59


50, 000 | 20
275,000

N/A

50,000] 100
i




125, 000 | 46
New York 120,000
Puerto Rico 104,000
Region III
Pennyslvania 110,000

Maryland 137,000
Delaware 33,000
Virginia

West Virginia

Reqion IV
Florida
Georgia

Kentucky

Tennessee

North Carolina
»
South Carolina

Mississippi

250
25

193

40
40
137,000) 42


32,000) 36




!
148,917] 131
|
141,260) 259

-


-

101,260] 201


60,000] 232
I
75,000| 196


38,763] 304


1 OF t OF
MEGHAN- JDUCNOS-
ICAL TIC EVAL
PLANTS tUATIONS
I
I
82 | 19
65
96
59

20
N/A

100


46
250
25

193

40
40
42

36


129
179



152

204
103

39
20
13

8
20

14


20
32
10

20

20
15
10

20


10
20


* PROVIDED
ONSITE TNG
/TECHNICAL
ASSISTANCE


6
16
6
12

1
20
ft OF ft SHOWING
PLANTS ] PERFORMANCE
BROUGHT IN] IMPROVEMENT
COMPLIANCE


6
10
5
7

~
17

3


10
14
10

10

12
8
10

20
32*

10
1


3
3
1

4

9




16*

8
14 6

22* 10*


—
6
-
5

~
3




2
-
ft PLANTS
STILL IN
TRAINING


6
9
-
12

1
20

3


10
14
10

4

2

1 3
-



6*

1
-

8*
8
10

10
10*


8

8*

21 16 11 3 10
14* 8* 3* 5*
25 10 3 4 10
30 16 5 7 9
34* 19* 9* 6*
58 | 10 36* 14* 17* 5*

Alabama 54,800| 211 107 10 -
1
t 1 t
                                                          -53-

-------
                                                             ATTAOWENT C
                                                             Page 2 of 3
            STATUS OF STATE ONSITE OPERATOR TRAINING
AND TECHNICAL ASSISTANCE PROJECTS FUNDED IN FY 1982 AND PY 1983
STATE
Region V
Illinois
Indiana
Michigan
Minnesota
Ohio
Wisconsin
Region VI
Arkansas
Louisiana

New Mexico
Oklahoma
Texas
Region VII
Iowa
Kansas
Missouri
Nebraska
Region VIII
Colorado
Montana
North Dakota
South Dakota
Utah
Wyoming


82/83
ALLOCA-
TION

$180,000
63,184
40,000
65,966
40,000
78,850

180,000
102,000

100,000
270,000
140,000

236,000
222,000
237,000
158,000

143,000
78,000
60,000
88,000
143,000
130,000


t PLANTS IN
STATE UNDER
5 MGD BUILT
W/FEDERAL $

377
232
263
330
302
423

280
221

127
456
782

702
707
688
348

156
124
235
188
80
66


# OF
MECHAN-
ICAL
PLANTS

377
232
263
330
302
422

120
137

117
252
666

323
474
371
174

123
39
3
42
24
10


* OF
DIAGNOS-
TIC EVAL
UATIGNS

7
15
10
10
8
11

32
22

18
48
37

85
50
40
21

21
16
95
14
5
6


t PROVIDED
ONSITE TNG
/TECHNICAL
ASSISTANCE

7
15
10
10
8
11

18
16
*7
6
42
15

49
33
36
21

16
10
95
14

6

-5
t OF
PLANTS
BROUGHT IN
COMPLIANCE

4
5
4
-
2
6

7
«
*2
5
20
15

19
25
31
15

6
3
-
2
-
-

4-
1 SHOWING
PERFORMANCE
IMPROVEMENT

2
2
2

4
5

4
2
*4
1
-
-

16
2
-
2

-
1
1





4 PLANTS
STILL IN
TRAINING

7
10
10
10
8
11

11
16
*4
3
34
15

16
7
12
3

2
-
41
-
-
_ *



-------
                                                             ATTACHMENT C
                                                             Page 3 of 3
            STATUS OF STATE ONSITE OPERATOR TRAINING
AND TECHNICAL ASSISTANCE PROJECTS FUNDED IN FY 1982 AND FY 1983
STATE

Region IX
Arizona
California
Hawaii
Reaion X
Alaska
Idaho
Oregon
Washington

















-
82/53
ALLOCA-
TION

$ 35,000
163,000
25,000

40,000
178,000
132,000
155,000


















'"# PLAINS IN-
STATE UNDER
5 MOD BCTILT
W/PEDERAL $

50
365
16

22
145
# OP
MECHAN-
ICAL
PLANTS

25
360
16

20
35
183 I 153
322 ! 302
1

I
1
1
1
» OP
DIASNOS-
TIC EVAL
UATIOSS

-
30
5

17
49
43
12
a PHOTO*
ONSITE TNG
/TECHNICAL
ASSISTANCE

-
7
2

6
7
5
8
i
i








1 i
I







i
i




|
# OF
PLANTS
BROUGHT IN
COMPLIANCE

-
3
1

-
1
2
-












# SHOWM
PERFORMANCE
IMPROVEMENT

-
3
-

1
-
1














1 1 \
\ \





















j PLANTS
STILL IN
TRAINING

-
4
-

6
7
1
3


















                                      -55-

-------
flu
Q
i
s
6







1
i
*
Z
^«

I
0
A
y











ggg
£ *• H
Bai
i s

pi
|_jj|
&*!!

a b. K En
s rii
i
S i
S • w
^ ^™* uQ Z £
JJoo*
0 Q 1 J tfl
slgas
Z M g w W
PS|
h '
fl C i
fe E H
ill2
SHO
3T ^ ^3
z 5 £
a i £

ORGANIZATION

§

— I •» V —t H ro r- *
-1 _ (N -H
So ro in -H r- oo
o oo >n c— .
 P*
« •-» ^- CM l*>  -H -H o 1 ^ 1
^H
o tn i/^ o o tf> co

in O
-^ o o o o tn i
o m ?N
iT» O l/> lA -^ -H *N
^
*fi o © Q r>< o v
O O krt Q \f\ ITI O
lf> ^ (N rl CN P* rO
^
O O O O O lA
H "-* C --H wj -"-f O M •*-* En O
8a*8 £ l» c~"S fi>H»§^"*
W C 03 -^ UC Cil C W C '— UJJ JCCC U3 C —
OQ-U O W 5w c *"u-^ OBI
M-i -^ C T3 u-f* UJ «-i -^H C Muia> tw Vj IM-^C
O AJ T3 C O->-> C>f O J-> 0 OE O *-i S O JJ Q
OJJ-^O A> O — ^ » 0$ U"""
» w w *o *w • -*H * ® to * n» • c •  *J -«-* ^S ^>«-**1 Jj iJ -.-1
p» O W Q fitO Q* S Q

Q|C CU > at Qi Q > fiT Cj W O a>£i m 3 oj ti **H Q) A aT-M C ftj t »M aa! z in XD r- -H O CM 1 O CM §in as CO CM 1 § 1 t (U 3 Dept. of Envirarm Conservation Department of Nat Resources £ BJ i i ve


-------
o.
Q
|
*fc
s








rM

5j
w
§
2
g

1
fe
0


So


















!ii
idg
£S
i s
uj C
pi
£ 3
o"ll
•*^ «*3 ^
tg &- g y>
f\ X *J

s u
S a
i
8 z
M M 2 fc;
lpP
Q ^
gpsi
^iii
£ — = g
^ 1^1
|i^
lls
lia

z o u.
Si|

5 &• oS
z O U


j



a
<£
S


9s O O 00 ON
f*1 O f*1 fM ^~i


^ r- 00 vo m

in in
o • os
^ M in os
m \o •*
oo m
m » r- in -H
o -H n m

r-

O> 00 O 1 O

O O O 1 O


O O O 1 O

o o <*> o
m o n i i-i
•— i
/v fl O
i o m r flo
O mo
ITJ O ffl 1 rH
iTl VO O O O
i-H
in o o ON o
\£) ~* O ^ i— I
•* fS

o o o irt
CO O O ^
i >• j-> c c 4J « iQC S3
c pi •" 3 •" 5
— 3 $ C £4J 5^-1
C O -i 3 I) 4JIB Ci a
•FH^^^ e •u'D •— 10 ^a
IB C C iBkj 103 >'H
^WCJ O 4->5 ^*t3 CO
^^>,° "'S31 "'S
Q>klJJ14J 10 UJ1M U-l3
4JIB-- 0 » — •rj OO OIC
io.ce ucp -~ o
4JU3 ••"•• *^M ••XI »»*^
111 Ji II III III
< "
M Z
5 3
o y < x
Z )-3 t— i *H itf
3 >• z > 5
i 1 s s 1
i s > s a


•* 0  rsi p-<
* in o T
in v o in
-H
m en
o m o v


ac
in o O o
ss
i -t I m


1 1 (N

o oo o
i m ip in
o -H m
I in CN m
. " S °°
moo
os O in
1 ~* S m
in N *


m m o o
-H r- o ^
in I-H o ^^
In

O ^4 u

 4J E ••H fl)
gj y c p x w p^s
C H CJ CX, U> C 0) — <
U •f-l .^H U •*-! <0
tj^e-*- ^'™< > O .^Hfc,.^
-r" A J3 -u fl c > >
> (A •v *»^ *J UJ *• C * *^
CC^ >-HC C UCQ
wOo (ooj "^0 0
-^ ^-t 5 g C O -*H yj -4 M
^ jj o c o jj c *J i1
OtOU p-^ 30 00
—t UdU fl}$kj *$•!-<
P( Si c jj > > ij O ^ CX O *•<
A ^ ^ S ^- pp^ 3 ^ -S JK^$

k™l
a.
S
S 5 s £2
| § i g
^ o S £
0
M
S
^


00
CM













S
o
1C
o
§
o
8




i

|
— 1 IB
of Environmenta
. , (Operations Br
II

uJ

_
1
z
 I
r-

-------

-------