United^tates
Environmental Protection
Agency
Office Of Water
(WH-546)
21W-7002
March 1991
&EPA
Municipal Water Pollution
Prevention Program
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MUNICIPAL WATER POLLUTION PREVENTION
March 1991
U. S. Environmental Protection Agency
Office of Water (WH-546)
401 M Street, S. W.
Washington, D. C. 20460
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EPA PROGRAM
TO PROMOTE
MUNICIPAL WATER POLLUTION
PREVENTION
I. EPA'S POLLUTION PREVENTION
APPROACH
The Pollution Prevention Act of 1990 estab-
lishes pollution prevention as national policy. The
Act sets forth a formal legislative charter for the
Agency to establish programs to promote pollution
prevention. In the Act, Congress "declares it to be
the national policy of the United States that pollution
should be prevented or reduced at the source when-
ever feasible; pollution that cannot be prevented
should be recycled in an environmentally safe
manner, whenever feasible; pollution that cannot
be prevented or recycled should be treated in an
environmentally safe manner whenever feasible;
and disposal or other release into the environment
should be employed only as a last resort and should
be conducted in an environmentally safe manner."
Through this statement, the Act establishes the
pollution prevention "hierarchy." The Agency
will, to the extent possible, encourage practices
which shift activities upward within the hierarchy,
with source reduction as the most preferred option.
For clarity within the pollution prevention
hierarchy, EPA has defined strict "pollution pre-
vention" as the use of processes, products or prac-
tices that reduce or eliminate the generation of
pollutants and wastes, including those that protect
natural resources through conservation or more
efficient utilization. Pollution prevention can be
achieved by reducing reliance on toxic raw mate-
rials, by changing processes through increasing
efficiency, and by changing outputs.
The Municipal Water Pollution Prevention
(MWPP) program encourages municipalities to
apply elements of the pollution prevention hierar-
chy. Publicly owned treatment works (POTWs)
not only discharge waste water, but may contribute
to the releases of various air emissions and solid
waste streams as a result of their activities and the
activities of their indirect dischargers. MWPP
may also play a valuable part in addressing releases
of various air emissions and solid waste streams.
There are additional opportunities to achieve pol-
lution prevention through industrial source re-
duction under the pretreatment program.
H. MUNICIPAL WATER POLLUTION
PREVENTION
The vast majority of Americans today are
enjoying the benefits of clean water. Since passage
of the Clean Water Act (CWA) in 1972, federal,
State and local governments have produced real
improvements in water quality. Consequently,
capital investments, supported by effective en-
forcement activities, have resulted in 90 percent of
the nation's major POTWs being capable of meet-
ing permit limits. We must now maintain this
significant and valuable investment to ensure con-
tinued environmental health, water quality, and
economic well-being for future generations. As
EPA, the States, and local governments address
new challenges in the areas of municipal growth
and newly regulated pollutants, we must also en-
sure a viable wastewater treatment infrastructure.
EPA will promote municipal water pollution
prevention by supporting and encouraging States
to develop programs that provide for the imple-
mentation of a variety of pollution prevention
activities and maintain municipal wastewater
treatment facility permit compliance. This repre-
sents a significant shift from current practices by
stressing a preventive approach to water pollution
abatement rather than one of remedial action. The
program is directed at preventing pollution from
both influent to the POTW and through activities
at the plant.
Successful State MWPP programs should
include:
MWPP Program
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a mechanism for routine assessments of the
compliance status of POTWs. Such a mecha-
nism often includes an early warning system
based on periodic self-audits and quantitative
techniques for assessing the condition of mu-
nicipal wastewater treatment systems.
a reporting process on the capability of POT Ws
to sustain compliance.
a process for identifying, implementing, and
tracking corrective actions to prevent pollu-
tion and maintain compliance.
a program that will encourage POTWs to
develop pollution prevention projects; for ex-
ample, loadings reduction projects and energy
and water conservation projects for household
dischargers might be promoted.
The MWPP program applies primarily to
POTWs that have the physical capability to com-
ply with their NPDES permit requirements. While
these facilities must continue to meet all compli-
ance deadlines, they may also begin to consider
pollution prevention opportunities. EPA will
continue to take vigorous enforcement action
against POTWs violating their NPDES permit
limits. For facilities under the MWPP program,
compliance with MWPP reporting requirements
and preventive measures will be stressed.
To implement successful MWPP programs,
EPA will work jointly with States and municipali-
ties to adopt pollution prevention programs that
attain the following objectives:
preventing violations of wastewater permit
requirements and maintain high POTW com-
pliance rates;
maximizing the useful lives of POTWs by
encouraging preventive approaches such as
improved operation and maintenance, appro-
priate pricing, financial management and ac-
counting practices, and reduced wastewater
flows and loading; and
ensuring timely planning and financing for
future needs and economic growth prior to the
occurrence of wastewater permit violations.
EPA recognizes1 that constructing adequate
wastewater treatment facilities is not sufficient.
MWPP programs should consider residential and
industrial programs designed to reduce flow and
loadings, which, in turn, reduce energy and decrease
demand for capacity. This approach, as well as the
recycling and beneficial use of sludge, is already
being undertaken in several communities across
the nation. Early problem identification, through
strategies based on pollution prevention, can sub-
stantially contribute to preserving our infrastruc-
ture and protecting our water quality in a cost
effective manner.
Juana S. Wilcher
Assistant Administrator for Water
MWPP Program
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MUNICIPAL WATER POLLUTION PREVENTION GUIDANCE
TABLE OF CONTENTS
PAGE
I. INTRODUCTION
Benefits of MWPP Programs 2
EPA/State Meetings/Workshops 3
History of the MWPP Concept 3
II. PROGRAM COMPONENTS AND OPTIONS
Early Warning Systems 4
Reporting Mechanisms 6
Corrective Actions and Program Management 7
Other Considerations 9
III. FUNDING FOR MWPP PROGRAMS
Existing Federal Funding Sources 10
Potential Federal Funding Sources 11
Alternative Funding Mechanisms 11
TV. EPA ROLES AND RESPONSIBILITIES
In Approved NPDES States 12
In Non-Approved NPDES States 13
APPENDICES
National Summary of Workshop Findings A-l
State Case Studies B-l
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MWPP GUIDANCE
I. INTRODUCTION
Since the enactment of the 1972 Amendments
to the Federal Water Pollution Control Act, more
than $73 billion in federal, State, and local funds
have been invested in the construction of munici-
pal wastewater treatment facilities. Moreover,
under the Environmental Protection Agency's
(EPA) NationalMunicipalPolicy, important strides
have been made to improve the ability of munici-
palities to comply with Clean Water Act permit
requirements. As a result of the large capital
investments and the National Municipal Policy,
the quality of our nation's municipal water pollu-
tion control infrastructure has significantly im-
proved.
EPA's recentNeeds Survey shows that, using
current approaches, as the population grows and
current treatment systems deteriorate more than
$80 billion in additional funds will be needed over
the next 20 years to keep pace with the need for
refurbishment and construction of additional fa-
cilities. Billions of dollars more will be necessary
for newly emerging needs associated with sludge
handling, storm water, combined sewer overflows,
toxics, and groundwater protection.
EPA believes that the most effective and equi-
table means of assuring viability of this infrastruc-
ture is through environmentally preferred pollu-
tion prevention approaches especially through ap-
plication of Municipal Water Pollution Prevention
(MWPP). These approaches may enhance worker
saftey, improve the usability of sludge, increase
the ability for local community expansion, and
reduce operation and compliance costs.
Pollution prevention can reduce the need for
substantial capital investment in new infrastructure
by emphasizing source reduction at the facility,
not increases in the size and complexity of the
treatment works.
In the context of the significant investment
which has been made in the municipal wastewater
treatment infrastructure over the last 20 years and
the planned termination of federal financial assis-
tance after 1994, there is a strong concern and
interest that:
the quality of the infrastructure be maintained;
facilities not be allowed to deteriorate;
municipal compliance rates remain high; and
degradation of water quality be reduced or
eliminated.
To address these concerns, EPA has em-
barked on a cooperative effort in partnership with
the States to promote State-based MWPP pro-
grams. States will have the flexibility to determine
whether to implement such a program and how to
design their programs.
As the federal government's role in funding
for construction grants ends, there is both a need
for and an opportunity to develop new strategies
which enhance and complement significant gains
made by this investment in our wastewater treat-
ment infrastructure. The primary goal is the
adoption of pollution prevention measures to meet
the expanding demands and extend the life of
existing facilities.
State-based municipal pollution prevention
programs focus attention on a series of actions to
prevent pollution in advance rather than taking
more expensive corrective actions. MWPP en-
courages resource conservation to reduce water
and energy use, appropriate pricing, toxicity re-
ductions at the source, BOD reductions, recy-
cling, proper treatment of wastes, and beneficial
uses of sludge. Toward this end, States should be
concerned with:
assessing the operations and physical capa-
bilities of municipal wastewater facilities on
a regular basis to determine their capability to
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MWPP GUIDANCE
meet treatment requirements both currently
and into the future.
monitoring a series of early warning indicators
which identify emerging problems before they
occur.
receiving reports on the performance of mu-
nicipal pollution prevention programs on a
regular basis so that necessary adjustments
can be made.
encouraging municipalities to take action long
before problems occur by holding municipali-
ties accountable for the implementation of
necessary preventive measures.
de: jaing mechanisms and enforceable tools
at the State level so that such programs are
adopted throughout the State.
providing necessary technical assistance by
the State and EPA to help get these programs
established and to help municipalities assess
the condition of their facilities and undertake
preventive actions on a regular and recurring
basis.
BENEFITS OF MWPP PROGRAMS
MWPP is an improved approach to managing
and regulating municipal sewage treatment facili-
ties. An aggressive, anticipatory approach has
potential benefits for everyone with a responsibil-
ity for such facilities.
Local Communities
For the operator of a treatment plant, a periodic
assessment of the status of the plant against explicit
criteria yields important information which helps
the operator look for new opportunities to encour-
age pollution prevention, to diagnose emerging
problems and to design actions to deal with them.
A requirement for the responsible local officials to
review and approve a systematic report provides
an opportunity for the opera tor to brief the officials
on the status of the facility and to bring
recommended corrective actions to their atten-
tion.
The local decision-maker benefits from a
greater understanding of the publicly owned
treatment work (POTW) and its role serving the
community. Early warning about future needs
allows the local official to plan ahead to avoid
such expenditures or to plan for and rank capital
needs. Periodic information also enables local
decision-makers to factor prevention and/or in-
frastructure investment considerations into any
economic and population growth plans or devel-
opmental strategies the community may have.
Finally, sound operation of the facility contributes
to the quality of life in the community through
improvements in health, aesthetics and recre-
ational opportunities.
State Governments
MWPP will assist States in meeting their
water quality objectives and prove to be a powerful
tool for maintaining high compliance rates. To
the extent that the useful life of facilities can be
extended through prevention, flow reduction, and
sound maintenance ormore efficient use of existing
capacity, future capital needs to finance the re-
placement of current plants may be reduced or
deferred.
Federal Government
Many of the benefits listed above are benefits
to the federal government as well since it shares
the same objectives. This is especially true in
States where EPA is responsible for administer-
ing the National Pollutant Discharge Elimination
System (NPDES) program.
MWPP will contribute to the protection of the
federal investment in munici pal sewage treatment
facilities. It also serves a major Agency priority,
pollution prevention, in two important ways. First,
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MWPP GUIDANCE
preventive actions may often include appropriate
water pricing, upstream water conservation, tox-
icity and BOD reduction, or infiltration/inflow
control measures that could reduce or defer facil-
ity needs. Second, contaminants are prevented
from being discharged to receiving waters. Since
planning and constructing facilities often takes
years, a preventive approach avoids years of dis-
charges above environmentally desirable levels
while the necessary improvements are put in place.
EPA/STATE MEETINGS/WORKSHOPS
In FY 1989, EPA conducted two meetings
with State and Regional representatives to discuss
MWPP program development. At these meetings,
EPA and the State representatives concluded that:
MWPP programs should contain some type of
early warning system and a rating system to
identify POTWs with potential problems.
MWPP programs should cover all effluent
limits and consider the entire sewer system,
not just the treatment works.
Municipalities should plan for future finan-
cial conditions.
EPA decided as a result of these meetings to
conduct joint workshops with the States. In an
attempt to include all the Regions and States in the
decision-making process, EPA held four Regional/
State workshops on the MWPP program between
November 1989 and January 1990 in Kansas City,
Missouri; WindsorLocks, Connecticut; Charlotte,
North Carolina; and Denver, Colorado. The key
findings and a detailed summary of the workshops
are contained in Appendix A.
HISTORY OF THE MWPP CONCEPT
The concept of developing programs to main-
tain POTW compliance was first identified at the
State level. As illustrated in the descriptions of a
few of the existing or piloted programs, MWPP
approaches are varied (see Appendix B for de-
tailed descriptions of the Wisconsin, New Mexico
and Texas programs). Programs need to be flex-
ible so they can be tailored to the specific needs of
the State and municipalities. A sound MWPP
program that achieves desired effects need not
necessarily encompass all aspects recommended
in this guidance.
The Wisconsin MWPP program was devel-
oped over a five year period with direct involve-
ment of those most affected by the program in-
cluding municipal government officials and POTW
operators. This resulted in a comprehensive, widely
supported program with an early warning system
to identify potential problems prior to noncom-
pliance. In addition, the Wisconsin program's
planning aspects have in some cases extended to
targeting recruitment of specific industries to
maximize use and capabilities of local POTWs.
Concurrently, other pollution prevention ac-
tivities were beginning at EPA. EPA encouraged
a new emphasis on pollution prevention. EPA
began to study ongoing pollution prevention ef-
forts by States, local governments and industries.
The Agency observed that some cities, like
Hayward and San Leandro in California, focused
on working with existing industries to promote
source reduction. Seven POTWs in North Caro-
lina provide on-site pollution prevention technical
assistance to industrial dischargers to the POTWs.
In Suffolk County, New York the POTW requires
businesses to identify pollution prevention tech-
niques that could be employed when applying for
a wastewater discharge permit. In some of these
cases, waste streams were altered or eliminated
resulting in decreased monitoring and reporting
costs.
H. PROGRAM COMPONENTS AND
OPTIONS
Effective and successful State-based munici-
pal pollution prevention programs include several
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MWPP GUIDANCE
components. This section explains these compo-
nents and provides options and procedural factors
for States to consider in developing their MWPP
programs.
EARLY WARNING SYSTEMS
A common factor leading to noncompliance
is the failure of a community to adequately plan to
meet existing and future needs, either through
prevention-based programs or through timely con-
struction of new or expanded facilities.
A major component of any MWPP program
should be the assessment on a regular basis of the
operational and physical capabilities, and finan-
cial status of the wastewater treatment infrastruc-
ture. Systems may be developed which require
municipalities to report performance against a
series of indicators and parameters which can
identify pollution prevention opportunities and
provide early warning of potential future pollution
orcompliance problems. An early warning system
will enable States and municipalities to identify
problems early and allow municipalities to take
appropriate corrective action before violations oc-
cur.
The precise form of an early warning system
can vary from State to State depending upon the
availability of resources and each State's program
implementation philosophy. There are a number
of potential early warning criteria from which a
State might select indicators. The following is a
list of indicators that should be considered in the
development of the MWPP early warning system.
However, this list is not exhaustive. EPA urges
States to consider including multiple indicators to
identify problems.
Influent actual flow versus influent design
flow: detects potential for future hydraulic
overloading of the system; overloading is usu-
ally caused by excessive storm water runoff or
extensive growth.
Actual BOD5 loading versus BODS design
loading: detects potential for future organic
overloading of the system; overloading is usu-
ally caused by municipal and industrial growth.
Potential for community and industrial growth:
anticipates future residential and industrial
pretreatment problems with hydraulic, toxic
and organic loading.
Number of overflows and bypasses of the
system: anticipates problems with surface
water quality due to untreated wastewater by-
passing the system; usually caused by heavy
rainfall or snowmelt or equipment failure.
Operator training and certification practices:
anticipates potential operation problems due
to improperly trained personnel.
Sludge storage and disposal capacity: antici-
pates future capacity shortages of sludge stor-
age and disposal.
Facility age: anticipates future maintenance
problems due to an aging facility.
Effluent quality versus permit limits: analyzes
past violations of effluent limits and indicates
the existence of treatment efficiency and op-
eration problems.
New requirements: anticipates the impact of
changed standards or permit modifications for
toxic discharges, sludge and combined sewer
overflows.
Financial status of the facility: anticipates the
facility's fiscal ability, both now and in the
future, to maintain, make improvements or
expand the wastewater treatment system, in-
cluding a review of the adequacy of the facility's
user charge, water pricing policies and cost
accounting systems.
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MWPP GUIDANCE
A State might elect to monitor any number of
these or other indicators, depending upon the fea-
sible and desired level of detail. Generally, the
greater the number of indicators selected for moni-
toring the more likely that the early warning sys-
tem will detect a potential problem.
For some States, selecting a large number of
indicators may not be feasible because of the size
of the State and number of POTWs. In such cases,
the States may choose to evaluate POTWs based
on a few indicators or criteria. For example, If a
treatment facility consistently operates very near
its design capacity, it is likely that the system will
be both hydraulically and organically overloaded
and that the facility's treatment efficiency and
effluent quality will be negatively affected.
Therefore, comparison of the actual flow through
a treatment system versus the design flow or per-
mitted flow of the system is an appropriate indica-
tor, although not necessarily the only appropriate
indicator, of the overall potential for future com-
pliance problems.
In addition to selecting a set of indicators, each
State should determine how it will evaluate the
information generated by the indicators. The
evaluation procedure may consist of a point sys-
tem that produces a score for each facility based
upon the selected indicators. Alternatively, a State
might establish thresholds for an indicator and
evaluate the facility based upon whether or not it
exceeds the thresholds.
For whichever system it uses the State should
define "trigger points" that require some action by
the State, municipality, and facility. The State may
have a system of escalating responses as a facility
reaches increasing point totals or surpasses thresh-
old levels. Finally, the point system or threshold
levels might be used as an initial screening device
and address the problems at potentially trouble-
some facilities on a case by case basis.
Three possible options for structuring an early
warning system are presented below. The first two
options involve using a point system to evaluate a
set of early warning indicators; the third option
involves using a.threshold criterion to evaluate a
single .indicator.
Option 1: Set of Indicators/Point System/
Escalating Response
An effective method of evaluating a set of
early warning indicators is to assign a point scale
to each indicator and to add the points for each
indicator at a facility to obtain a total score for the
facility. The number of possible points assigned to
aparticularindicator would depend upon the State's
assessment of that indicator's importance.
A State may also decide to establish a system
of possible responses to the early warning indica-
tor scores. The level of State action should increase
asafacility'sindicatorpointtotalincreases. State
responses should range from "no action" for low
point totals to "formal enforcement" forhigh point
totals. State technical assistance and requirements
for planning and implementing facility improve-
ments and capacity expansion would be triggered
with median range point totals.
The State of Wisconsin has adopted the above
approach to evaluating indicators and determining
the appropriate level of State response. Wisconsin
has three levels of response for three different
point ranges. Any necessary corrective action by
the facility owner is voluntary at the lowest point
range. The State recommends operational and
needs reviews for facilities with middle range
scores and requires reviews and action plans for
high scoring facilities.
Option 2: Set of Indicators/Point System/
Individual Review
Some States may choose to use a point system
with the early warning indicators as an initial
screening tool for identifying facilities with po-
tential problems. A review board then identifies
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MWPP GUIDANCE
those facilities in need of individual assistance and
determines the proper course of State action.
The State of New Mexico took this approach in
evaluating data generated from its early warning
system. The State was able to take this highly
individualized approach due to the relatively small
number of facilities evaluated.
Option 3: Few Criteria/Threshold Exceedence/
Escalating Response
States with a large universe of treatment facili-
ties might choose to base their early warning
systems on a few criteria such as effluent flow
versus design flow, facility age and new require-
ments (see Chapter II, page 4). For example, a State
choosing this structure establishes increasing
threshold values for effluent flow based upon
specified percentages of the system's design flow.
If a treatment facility exceeds the initial threshold,
the State might respond with a recommendation
that the facility examine prevention-based strate-
gies, define its future capacity needs, and assess
cost effective options. At the median threshold
level, the State might require that the facility ini-
tiate planning for appropriate water pricing, water
conservation, toxicity reduction at the source, BOD
reduction, or other prevention-based measures.
Should such approaches be inadequate, plans could
then be made for facility expansion and improve-
ment. When the facility reaches the highest thresh-
old, the States might require that the facility begin
implementing its plan.
The State of Texas has adopted an early warn-
ing system based on an escalating response. When
flow measurements at a treatment facility reach 75
percent of its permitted flow for three consecutive
months, Texas responds with a letter to the permittee
requiring initiation of engineering and financial
planning for necessary facility expansion and im-
provement. At 90 percent of the permitted flow,
the permittee is required to obtain the necessary
authorization from the Texas Water Commission
to begin construction.
REPORTING MECHANISMS
The value of an .early warning system is en-
hanced if .the results are formally and routinely
reported to the local governmental decision-mak-
ers and the State so that proper planning and
corrective actions occur. The choice of a reporting
mechanism will depend upon the type of early
warning system and evaluation approach taken.
For example, early warning information may be
formally submitted in a report, taken from existing
data reports, or collected directly by the State.
These three options for reporting mechanisms are
discussed below.
Option 1: Self-Audit Reporting Form
A State that has developed a set of indicators
covering several aspects of treatment facility op-
erations mightdevelop a special reporting form for
recording indicator measurements and scoring the
facility on the basis of these measurements. This
type of form may require self-reporting by the
facility operators. The form should be reviewed by
the facility owner or the municipality before being
submitted to the State.
The State of Wisconsin uses a reporting form
for its early warning system. Facility operators
report information relevant to the early warning
indicators and use this information to score their
facilities. They also subjectively answer self-
evaluative information about the operations and
financial status of their facilities. After the operator
completes the form, the facility owner reviews it
and, based upon the scores, lists the steps it will
take to maintain compliance at the facility.
The local officials must file a certification with
the report that acknowledges the findings and
specifies, if appropriate, cost effective corrective
actions. This process forces the responsible offi-
cials to become aware of the status of the facility
and to commit to the necessary corrective actions.
The benefit of this approach is that local decision-
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MWPP GUIDANCE
makers must participate in determining what ac-
tion needs to be taken as opposed to being told by
the State.
Self-audit reporting forms are most suitable
for State programs that choose a comprehensive
set of indicators, when the desired information is
routinely available to the State. Financial status,
for example, is not now typically reported to the
State. At the same time, such reports imply some
additional work for State staff since the reports
have to be reviewed and evaluated.
Option 2: Existing Data
States evaluating a few indicators, including
effluent flow rate, may be able to use existing data
to monitor facilities. For example, facilities are
required to submit discharge monitoring reports
(DMRs) in which they report their effluent flow
rates. States could collect the information from
DMRs pertinent to the early warning evaluation
and make comparisons. The State of Texas uses
DMRs to collect monthly flow rate information for
facilities in that State.
Reliance on existing data has some advan-
tages: (1) it creates no new reporting burdens for
the operator; (2) the reports can be automated,
thereby reducing State workload; and (3) the
"trigger points" can be built into the automated
system, thereby simplifying the evaluation pro-
cess. A program relying on a single indicator is,
however, less comprehensive since no single in-
dicator is a good surrogate for all the potential
problems.
Option 3: State Inspections
State inspections might be an appropriate
technique for information collection in some States.
Inspections are particularly beneficial if they are
designed as comprehensive assessments of treat-
ment facility operations and used to supplement
existing State data on treatment facilities. Inspec-
tions allow the State to have a great deal of control
over the quality of information used to evaluate a
facility, but they also require more resources. Lim-
ited time, money, and manpower may prevent
States, from relying upon State inspections as the
sole approach to collecting the necessary inform a-
tion for early warning evaluation of treatment
facilities.
CORRECTIVE ACTIONS AND PROGRAM
MANAGEMENT
Corrective Actions
An effective State-based MWPP program es-
tablishes a set of processes to ensure that, once an
emerging problem is identified, appropriate cost
effective corrective actions are selected and carried
out in a timely fashion. The facility operator and/
or the entity responsible for it should bear an
enforceable obligation to identify and take cor-
rective action. There are several steps in the
corrective action process. First, since the early
warning system is a screening device, the facility
should undertake a more comprehensive analysis
of the potential problem. A formal analytical step
is less important in cases where a comprehensive
self-audit is required as the early warning system.
Second, since there are several possible solutions
to most problems, there should be an option se-
lection step where a course of action is chosen
based on pollution prevention potential and cost
effectiveness of alternatives. This program en-
courages such decisions to be based on the pollu-
tion prevention hierarchy. For example, where
municipalities are approaching capacity limits,
they may set specific goals to reduce flow, loadings
and toxic discharges through source reduction and
closed loop recycling activities, eliminating the
need for facility expansion. Finally, the action
plan should be implemented on a timely basis.
A significant element is the State's role in
corrective actions. At a minimum, States should
provide for a review and/or approval of proposed
corrective actions and track the adequacy of imple-
mentation. Additionally, States should have the
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MWPP GUIDANCE
ability to enforce MWPP requirements through
State laws, regulations, permit conditions, etc.
The response to failure to report or to take correc-
tive action depends on the State MWPP imple-
mentation philosophy and may involve such steps
as publicity on recalcitrant facilities, letters re-
quiring information or the preparation and sub-
mission of facility plans, sewermoratoria, admin-
istrative orders requiring action, court actions,
cash penalties.
States should consider including MWPP in
their overall Enforcement Management System
with definitions of appropriate enforcement ac-
tions for various violations and escalation of
enforcement responses in the face of continued
non-compliance. For example, delays in submit-
ting the annual report could be handled with a
warning letter. A sewer connection ban maybe
an appropriate response in the case of a facility
with capacity problems that has not adopted a
corrective action plan. Administrative orders
may be an appropriate response if major imple-
mentation milestones are not met. Obviously,
when untimely corrective action results in viola-
tion of effluent standards, the State may seek
penalties. States have already adopted enforce-
ment strategies for NPDES programs, and should
consider extending those strategies to cover
MWPP.
States should consider the role of technical
assistance to facilities needing corrective action.
New Mexico tested a program that was voluntary
for treatment facilities and relied entirely on in-
centives in the form of State assistance to per-
suade communities to participate. EPA, the States
and the private sector offer a host of technical
assistance programs to provide support to munici-
palities. These programs include operation and
maintenance, operator certification and training,
small community technology/financing, user
charge analysis, municipal technology transfer,
etc. In many States these programs have been
managed independently of one another. A well
executed State MWPP program would integrate
these various programs to support common State
pollution prevention objectives. An integrated
review of these programs can aid in preventing
pollution and noncompliance and help minimize
the need for more costly enforcement to assure
compliance.
Assistance to POTWs may also encompass
financial planning assistance and economic incen-
tives. For example, an innovative feature of one
existing State MWPP program is interest rate re-
ductions on State Revolving Fund (SRF) loans to
POTWs with good compliance records. This
contrasts with providing funds to municipalities
with poor compliance histories based solely on
needs. These innovative incentives encourage
POTWs to maintain compliance and create rewards
for exemplary conduct.
Management Tracking
An MWPP program should incorporate an
information and status tracking system for facili-
ties included in the scope of the program. Since the
implementation of some corrective actions may
take years, the system should have the ability to
track status for lengthy periods. Possible mile-
stones for tracking are:
Performance against early warning system
indicators
Timely receipt of reports
Timely review of reports
Dispatch of notification to facility
Review/approval of corrective action
Status of corrective action
Completion of corrective action
States that choose to develop a set of indicators
and a self-auditing form for facilities may wish to
PageS
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MWPP GUIDANCE
establish a computerized data base for storing and
analyzing the incoming data from facilities. A
computerized tracking system can be especially
useful for large States or States that choose to
monitor several indicators. Computerized track-
ing would also be useful when a data base contain-
ing the relevant information element already ex-
ists, such as DMR data. If early warning information
is tracked by computer, a computer program could
be easily created to automatically alert the State.
States that have a small universe of facilities
subject to the MWPP program and desire a more
individualized approach to addressing potential
compliance problems may choose to manually
track information. In New Mexico, a review
board, after an initial screening of potentially
troublesome facilities, recommends action on a
case by case basis. There is no formal automated
tracking system. This approach is less resource
intensive and may be appropriate for States with
fewer communities and a limited number of indi-
cators.
In any case, most States already have some
type of automated information system for munici-
pal facilities. When automated MWPP tracking
systems are desired, existing systems should be
evaluated to see if they can be adapted for MWPP
purposes.
Another aspect of tracking involves the dis-
semination of the information to the appropriate
State or external organizations that can effectively
utilize the data generated. Within the State agency,
units that deal with compliance, outreach, operator
training, user charge reviews, etc. should be pro-
vided access to the data.
Program Evaluation
An integral component of any program is a
mechanism to evaluate whether the program is
achieving its stated objectives. States are urged to
build the evaluation mechanism into their pro-
grams.
Quantifiable measures of progress are prefer-
able, although evaluations can be qualitative as
well. . Some possible measures for the MWPP
program are:
Trends in compliance rates
Number of facilities identifying potential
problems
Per cent of facilities completing corrective
actions on schedule
Compliance with MWPP requirements
Appropriate environmental indicators
Other possible measures may be activity indi-
cators, such as the number of facilities assisted by
the State. Whatever measures are chosen, it is a
good practice to establish a base line from which
progress can be measured.
OTHER CONSIDERATIONS
There are other issues a State should consider
in developing its municipal pollution prevention
program:
Which Facilities
States will need to decide whether all or only
some municipal facilities should be included in
State MWPP programs. One potential reason for
limiting participation is that large States with nu-
merous facilities may face resource constraints in
trying to apply the program to all their facilities.
Forexample, the program could be oriented towards
major facilities on the assumption that malfunctions
at major facilities carry a greater risk to human
health and the environment. Conversely, small
communities could be targeted on the assumption
that these facilities have a greater need for evalu-
ation or assistance than the majors.
P?ge9
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MWPP GUIDANCE
The States of Wisconsin, Texas and New
Mexico have chosen to address all wastewater
treatment facilities under their respective programs.
Obtaining Support
As they develop their programs, States should
consider the need to build support for the program.
For example, the State of Wisconsin invested
several years in the development of its program.
During this period, Wisconsin held 22 workshops
for elected officials, facility operators, public works
personnel and representatives of environmental
groups. It also established a 19-member advisory
committee which participated actively in shaping
the program. Wisconsin attributes the success of
its program to its careful developmental process.
At the other extreme, Texas, which tracks one
indicator through existing reporting mechanisms,
chose not to go through a similar process.
Some of the factors that may influence the
States' investment in consultation and generating
support include the complexity of the program, the
new burdens being placed on treatment facilities,
the extent of departures from existing procedures,
and the degree to which new requirements are
applied as part of the MWPP program.
FUNDING FOR MWPP
PROGRAMS
This section discusses various funding sources
for State development of MWPP programs. In
particular, it focuses on existing and potential
federal funding sources available to States.
EXISTING FEDERAL FUNDING
SOURCES
The existing Clean Water Act (CWA) authori-
ties offer opportunities for States to develop MWPP
programs. Several existing EPA funding sources
have been identified to assist States in MWPP
developmental efforts. These authorities are dis-
cussed briefly below, and fiscal year 1991 funding
levels are also provided. States and Regional
Offices will need to .negotiate use of these funds
during the. workplan development process.
Section 104(g) funds: Provide onsite assis-
tance to help small facilities with compliance
problems. Onsite assistance can include MWPP
activities intended to promote long-term compli-
ance, such as assistance with long-range capital
planning, reviews of user-charge systems, devel-
opment of self-auditing systems, and utility man-
agement training. Section 104(g) funds are gener-
ally used to support ongoing operational activities.
FY 1991 funding level: $2,050.0 K
Section 106 funds: Supplement State re-
sources for water pollution control programs.
Funding can include MWPP activities involving
permit issuance, enforcement, water quality moni-
toring, water quality planning and standards,
wasteload allocations, ground-water programs,
pretreatment, oil and hazardous materials spill
response, and general program management. Sec-
tion 106 funds can be used to support MWPP
program development activities or ongoing opera-
tional activities, including those associated with
MWPP. FY 1991 funding level: $81,700.0 K
Section 205(g) funds: Cover costs of manag-
ing delegated responsibilities under sections 201,
203,204,and212of the CWA, i.e., the wastewater
construction grants program. In addition, 205(g)
provides authority to States to cover costs associ-
ated with administering an approved program un-
der section 402 (i.e., implementation of MWPP
through the NPDES permit program), or a State-
wide waste treatment management planning pro-
gram under section 208(b)(4). Section 205(g)
funds may be used to support ongoing operational
activities only, including those associated with
MWPP.
Funding under section 205(g) has been autho-
rized through any fiscal year ending before Octo-
ber 1, 1994; Congress has not appropriated new
Page 10
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MWPP GUIDANCE
money for these purposes in FY 1991. Some
States have funds available from previous years
under section 205(g).
Sections 205(j) and 604(b) funds: Support
MWPP management activities in water quality
management planning. This set of activities could
include MWPP tasks associated with determining
and reporting the nature, extent, and causes of
water quality problems in various areas of the
State and interstate region. Sections 205(j) and
604(b) funds may not be used for program imple-
mentation activities. FY 1991 604(b) funding
level: approximately $20.4 M
POTENTIAL FEDERAL FUNDING
SOURCES
The following new sources of federal funding
can be used to support the MWPP program.
Section 104(b)(3) funds: Support grants or
cooperative agreements to finance the develop-
ment of a wide range of programs relating to the
causes, effects, extent, prevention, reduction, and
elimination of pollution. These developmental
activities apply directlytoMWPPprograms. Funds
can be used to conduct special activities, demon-
strations, training and studies in such areas as
permitting and enforcement, sludge management,
water quality standards, and water quality moni-
toring. Section 104(b)(3) funds cannot be used to
support ongoing operational ctivities. A portion
($500.0 K) of the FY 1991 funding has been
reserved specifically for MWPP pilot grants (as
described below). FY 1991 funding level:
$16,500.0 K
MWPP National Pilot Program Grants: The
Office of Water, in cooperation with the Office of
Pollution Prevention (OPP), plans to enter into
cooperative agreements with selected States dur-
ing FY 1991 to provide funding for MWPP pilot
programs. Awards will be made to States. Certain
matching fund requirements may apply. EPA is
preparing separate guidance for the Regions on
MWPP pilot grants which will discuss award crite-
ria, the grants process and matching funds. FY
1991 funding levels: $500.0 K from OPP for
source reduction projects; $500.0 K from OW
(reserved from section 104(b)(3) monies) for
MWPP program development and start-up
ALTERNATIVE FUNDING MECHANISMS
In addition to the grant funds discussed above,
States may also want to consider other funding
sources for development and implementation of
their MWPP activities. As part of the State Fund-
ing Study, the Agency has been working with the
States over the last several years to identify other
techniques which States might be able to use to
raise funds to manage State programs. Some of
these options collectively have been termed "alter-
native funding mechanisms" (AFMs).
AFMs may include a variety of approaches,
but can generally be grouped into four categories:
(1) fees, (2) taxes, (3) fines and penalties, and (4)
other. EPA publications which provide a good
overview of the current and potential applicability
of AFMs include "State Use of Alternative Financ-
ing Mechanisms in Environmental Programs" and
"Discussion Paper on Alternative Financing
Mechanisms for State Water Programs". In addi-
tion, the Agency is establishing an Environmental
Financing Information Network (EFIN) which will
assist States in accessing materials relating to AFMs
for State program management. EFIN will include
additional materials including State specific dis-
cussions of the use of AFMs. EFIN should be
accessible to the States in mid FY 1991.
Many States have already instituted AFMs for
a variety of environmental programs. There arc
opportunities for expanding the application of these
techniques to other programs and to other States.
The most common AFM approaches are outlined
below:
Page 11
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MWPP GUIDANCE
Fees
Permit issuance (e.g., NPDES, facility instal-
lation, review of proposed development)
Services (e.g., inspections, monitoring)
User charges (e.g., surcharge on wastewater
and/or solid waste disposal fees, hunting/boat-
ing licenses, access to recreation areas)
Impact charges (e.g., wastewater service sur-
charge based on toxicity, urban development
impact fee)
Taxes
Commodity (i.e., special tax on certain mate-
rials which contribute to water quality prob-
lems, e.g., selected pesticides and chemicals)
Special dedicated funds [e.g., mineral extrac-
tion tax, excise tax (e.g., boats, cigarettes,
hotel/motel)]
Real estate (e.g., transfer tax, environmental
review fees)
Sales, income, property (particularly if portion
is dedicated for water quality programs)
Fines and Penalties
As authorized for violations of environmental
requirements; more useful as a deterrent rather
than as a reliable funding source
IV. EPA'S ROLES AND
RESPONSIBILITIES
IN APPROVED NPDES STATES
EPA will undertake an active program to gen-
erate State and local support for MWPP. EPA will
assist the Regions in conducting workshops for
interested parties and provide training for plant
operators. The following paragraphs describe what
we believe to be the appropriate roles and respon-
sibilities for EPA.
EPA believes that MWPP is a logical and
necessary evolutionary step in the management of
municipal wastewater treatment facilities. There-
fore, EPA will continue to urge States to develop
and implement MWPP programs, although States
will have the flexibility to determine whether to
implement such a program and how to design their
programs. EPA will coordinate the identification
and use of appropriate forums to discuss MWPP
and generate a broad base of support for the ini-
tiative. A communication strategy, which identi-
fies key constituencies (e.g., local elected officials,
city managers, treatment plant operators, industry
associations, etc.), has been developed. EPA will
continue to work with the States in carrying out this
strategy.
EPA will provide support in a variety of ways
to States in developing and implementing their
programs. Among these are:
EPA will gather information on MWPP prac-
tices and experiences and make it generally
available.
EPA will prepare brochures and other support
material for the use of Regions and States in
developing programs and in working with
POTWs to implement programs.
EPA staff will provide advice and technical
assistance to States in developing and imple-
menting MWPP programs.
EPA will make available information on po-
tential sources of funding for MWPP pro-
grams.
Page 12
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MWPP GUIDANCE
EPA will make a limited number of incentive
grants from those funding sources described
above to foster the development of State pilot
programs.
EPA will fund State operatortraining programs.
EPA will gather periodic information about
the status and performance of State-based munici-
pal pollution prevention programs. EPA will ob-
tain the necessary information through its existing
oversight of State activities. To assess progress,
qualitative measures may be included in the Office
of Water Accountability System.
IN NON-APPROVED NPDES STATES
In States where responsibility for the NPDES
permit program still rests with EPA, the cognizant
EPA Region will be responsible for developing
and implementing MWPP programs. However,
Non-NPDES States are encouraged to participate
in this program. The Region will use its discretion
to tailor a flexible program that meshes with the
State's legal authorities and preferences.
Programs for Non-NPDES States will include
the components described in Section n of this
Guidance: early warning systems with periodic
self-audits, a reporting mechanism, corrective ac-
tions, tracking systems, and a process for program
evaluation. EPA will support the objectives of the
program through all appropriate means including
NPDES permits. Programs forNon-NPDES States
will be developed and the workshop/training effort
will be initiated in FY 1991.
Page 13
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MUNICIPAL WATER POLLUTION PREVENTION (MWPP)
APPENDICES
Prepared by the Office of Municipal Pollution Control
and the Office of Water Enforcement and Permits
-------
TABLE OF CONTENTS
APPENDIX A: National Summary of Workshop Findings
APPENDIX B: State Case Studies
Wisconsin
Exhibit 1 -- Wisconsin Administrative Code Chapter NR 208
Exhibit 2 -- Compliance Maintenance Annual Report Instructions
Exhibit 3 -- 1987 Compliance Maintenance Annual Report
Texas
Exhibit 1 -- Excerpt from 31 Texas Administrative Code Chapter 305
Exhibit 2 - Letters Sent to POTWs at 75 and 90 Percent Capacity
Exhibit 3 -- Graph of Combined Total of 75-90% Letters Mailed
Nex Mexico
Exhibit 1 -- New Mexico IMPAC Questionnaire
-------
MUNICIPAL WATER POLLUTION PREVENTION (MWPP)
APPENDIX A
National Summary of Workshop Findings
-------
MWPP WORKSHOP SUMMARY
Should there be an MWPP Program?
States generally reacted favorably, to the MWPP concept.
Several States (in 4 of the 10 Regions) acknowledged that many of the MWPP components
are already in place. These pieces, however, may not be well-integrated to form a cohesive
and comprehensive program.
Should the Program be Voluntary or Mandatory?
The States were unanimous in wanting the MWPP program to be voluntary, with maximum
flexibility for the States to design their own programs.
States in half of the Regions felt that the MWPP program should be mandatory for POTWs.
States in 2 Regions thought that the program should be voluntary for POTWs.
What Universe Should be Addressed?
Almost all of the States (9 out of 10 Regions) agreed that the program should address both
majors and minors. Several States emphasized that minors oftentimes present the worst
problems.
There was varied opinion, however, on who should be addressed first. States in Regions I
and II would prefer to phase in majors first. In contrast, States in Region X would address
smaller facilities first
Should there be Uniform National Indicators?
Except for the States in Regions VI and VIII, where there was no answer, all of the remaining
States were unanimous in wanting flexibility to develop their own indicators.
Should the Program be Oriented Towards Technical Assistance or Enforcement?
States in 5 of the Regions showed greater preference for technical assistance.
However, almost all of the States recognized the need for both elements in the MWPP
program.
What should be the Focus of Enforcement?
States in only two of the ten Regions would use enforcement before effluent violations
occurred.
The remaining States believe that it would be difficult to enforce before there were effluent
violations.
-------
MWPP WORKSHOP SUMMARY
What should be the Focus of Enforcement (continued)?
o These States would prefer to use other tools to enforce MWPP, e.g., sewer bans, TAP ban, or
provide special incentives such as a discounted interest rate for SRF loans.
What are the Resource Implications?
States in 4 of the 10 Regions responded that it will take at least 1-2 FTE to get the program
started. Other estimates ranged from 1-6 FTE.
States in half of the Regions stressed that the resource demands will vary by size and scope
of State program, and that it is difficult to assess.
States in only two of the Regions believed that there may be some future resource savings as
a result of reduced enforcement efforts.
What are Possible Funding Sources?
States in only 4 Regions provided a response, stating that possible funding sources include:
pilot project grants
SRF
4% set-aside
205(g)
104(g)
permit fees
All of the remaining States raised serious questions concerning possible funding sources and
eligibility of MWPP under SRF.
What Incentives Are Available to Encourage State Participation?
The number one incentive is increased funding.
In addition, States in 7 of the 10 Regions recommended that EPA and the States develop
strong selling programs through workshops and informationAechnology transfer. They also
emphasized the need for extensive public participation and public involvement in the
development and selling of this program.
What are Realistic Time Frames for Implementation?
For States in 6 of the 10 Regions, estimates to initiate the MWPP program range from 1-3
years.
For States in 3 Regions, the programs could be fully operational within 7 years.
-------
MWPP WORKSHOP SUMMARY
What are Appropriate EPA Roles In Supporting the MWPP Program?
The majority of States (7 from 10 Regions) agreed that EPA shquld provide examples of
MWPP models and indicators, which the States would then modify to fit their own needs.
States from 4 Regions also recommended that EPA act as a national information
clearinghouse and provide technology transfer, as necessary.
-------
Issues
Regions I & II
Munkpal VViitcr Pollution Prevention Workshop Issue Summary
Region III Region IV Region V Region VI Region VII Region VIII
Region IX
Region X
Should there he «n
MWPP program?
Should the program
be voluntary or
mandatory?
STATES?
POTWs?
What universe
should be addressed?
Should there be
uniform national
Should the program
be oriented towards
technical assistance
or enforcement?
What should be the
focus of enforce-
ment?
Liked the concept.
Voluntary; provide
flexibility for States
to develop own
program.
Voluntary
Phase-In majors first;
than an POTWs.
Allow each State to
develop own set of
iiiuivaioi s ciMracn
from national list.
Objective Is compli-
ance maintenance
proactive program;
not an enforcement
program.
Do not use report for
enforcement; MWPP
can he enforced using
looh outside of
permit.
Mrongley support
MWPP.
Voluntary
Mandatory
AD major and
minors.
States should design
their own program.
No consensus; prefer
technical assistance
program, but
recognize enforce-
ment Is needed.
States should pursue
enforcement before
effluent violations; In
practice, enforcement
will probably follow
violations.
Program Is promis-
Ing.
Voluntary at first;
mandatory later If
necessary.
no answer
Majors and minors,
but leave decision up
to states.
Allow States to
develop own Indica-
tors.
Technical assistance;
especially training;
enforcement will still
be required.
Effluent violations
Yes; must of the
elements of MWPP
are already in place.
Voluntary; pro-
grams should be
Slate-specific.
Mandatory; hut
public support
should he established
flrrf
Majors and minors;
minors need more
emphasis.
States should develop
Indicators; national
Informational only.
no answer
no answer
Support concept;
pilot programs being
conducted In I.A.TX,
and NM.
Voluntary; any
statute should read
"may" not "shall".
Mandatory
All POTWs; minors
are the biggest
concern.
no answer
Provision In permit
for technical
evaluation of
sewerage system.
Emphasize enforce-
ment of effluent
violations; also need
ability to enforce
before violations
occur.
Yes; Stales are doing
most of the Wl
program already.
Voluntary; flexibility
achieves results; do
not Just count beans.
Voluntary
no answer
All aspects of
program should be
voluntary.
Technkal assistance
no answer
Yes; program must
be flexible and State-
specific.
Voluntary
Mandatory; one
State believed region
should prepare
rpnnrt.
If mandatory,
majors; If voluntary,
majors and minors;
emphasis on minors
and mechanical
olants.
no answer
Not Just enforce-
ment; a mix of
technical experience
and enforcement.
Focus on violations;
difficult to enforce
beforehand; use TAP
ban and discounted
Interest rates as
Incentives.
Support ideas, hut
pollution prevention
is goal of existing
State programs;
priorities need to set.
Voluntary
no answer
Any facility that
treats domestic
sewage; not Just
municipals.
States should have "
flexibility to develop
A sliding scale;
elements of both.
Varies by State;
other actions (sewer
bans, etc.) are also
useful.
\ es; many places
already exist in the
States.
Voluntary
Mandatory
Smaller facilities
first; most sensitive
resolving areas first;
let Slates decide.
Flexibility in key.
Could he either or
both; leave decision
to Stales; add
financial assistance.
Could he either or
both; leave decision
to Stoles.
-------
Issues
Regions l&ll
Municipal Water Pollution Prevention Workshop Issue Summary (continued)
Region 111 Region IV Region V Region VI Region Vll Region VI11
Region IX
Region X
What are the
esource Implica- .
ions?
What are possible
unding sources?
What Incentives arc
ivallable to encour-
ige Slate partkipa-
Ion?
What are realistic
ime frames for
mpkmenlation?
toles for EPA
24FTEs;2FTE
Initially and 2-4 FTE
to maintain; will vary
by size of State and
program.
EPA pilot project
grants; HQs fund
program guidance;
104(g); contract
funds.
Funding! Sell
program to local
officials; extensive
public Involvement
up front; reduce
enforcement and
emphasize MWPP.
Varies by State;
range from 2-10
years to generate
support within Stale
and begin Implemen-
tation.
Provide example* of
early warning/point
system for States to
modify. Program
components and guld-
dance developed at
national level.
1-4 FTEs; savings
passible due to less
enforcement; State-
specific and depen-
dent upon Intensity
SRF funds; 4% set-
aside; 205 (g) and 106
funds; permit
fees and State
. .
appropriations.
Develop strong out -
reach program; pro-
mote public Involve-
ment; EPA should
develop national
policy statement.
Deadlines not
needed; give States
chance to develop
own time tables.
EPA provide model
and function as
national clearing-
house; States decide
which part of model
fits their needs.
Administrative costs
are not high; States
will have to divert
resources from other
programs over short-
run.
SRF funds; 4% set-
aside; 205(g); permit
fees and State
appropriations.
Funding; support for
State's selling
program; provide
Incentives for States
that participate early
on.
Range from 1-7
years.
EPA develop model
with thresholds;
States adapt model to
their own needs.
fcxpanded program
will require addi-
tional resources.
no answer
.
*
Funding) Seed
money.
no answer
Generate list of ideas
for program ele-
ments; set up
national steering
committee; HQs acts
as facilitator.
Increased resource
demand to get
program running (2-
3 years); eventual
stabilization and
possibly a decrease in
resource demand.
EPA should delineate
eligible sources;
Slates should
establish priority
funding for compli-
ant facilities.
EPA should allow
Stales to amend work
plans and grant
commitments; focus
on new priorities.
2 years lo start; fully
operable In 6 years.
Develop national
policy statement;
encourage program
flexibility; publk
education.
A lot!
Resources are bk>
Issue and questions
whether EPA will
provide 106 set-sides,
lift 4% SRF lid?
EPA contract funds?
Really need to sell to
dischargers.
Except for Missouri
implementation will
lake 1-2 years.
Develop examples
of MWPP; not
guidance. Identify
program Impact and
need for CWA
amendments.
MWPP effort must
remain discretionary.
varies by Mate and
scope of program; no
on funds means no
program.
no answer
Money; low interest
rate loans; allow
Stale to design
program.
Dependent on
available rsources
and scope of
program; up to 6
years (12-16 months
to Initiate).
Provide technology
assistance and
transfer; respect
State decisions;
recognize that State
programs may be
enough.
^
Depends on program
structure; voluntary
has minimal resource
Implications.
Uncertain; is it SRF
fundabk?
States are already
Involved; more
training opportuni-
ties; workshops
increased Incentives.
Difficult to deter-
mine; States have
already started; it's a
continuous process;
depends on profile of
program.
Provide different
model warning
systems; various
scenarios; try to get
ASW1PCA Involved;
EPA must be flexible.
Mo consensus;
depends on structure
of program; 1-5
FTEs (estimation).
Depends on whether
program Is voluntary
or mandatory; SRF Is
not a good source.
Money; allow States
to create own
program; workshops;
extensive public
participation process;
techincal assistance.
1 -3years(estimale);
must be a grass root
ImplemenU Ion
process.
Keep program
flexible;
minimal tracking at
national level; EPA
should sell program;
a Federal/Slate
partnership.
-------
MUNICIPAL WATER POLLUTION PREVENTION (MWPP)
APPENDIX B
State Case Studies
-------
STATE CASE STUDIES APPENDIX B
APPENDIX B: State Case Studies
INTRODUCTION
This appendix contains case studies of three innovative MWPP programs: the Wisconsin
Compliance Monitoring Program, the Texas 75-90% Program, and the New Mexico IMP AC Program.
Each case study presents the history of the State's program, how the program was planned and developed,
and how the program operates. All of the case studies also include a section about the types of resources
(personnel, funds, equipment) which the program requires.
By including these examples in the guidance document, it is hoped that other States will better
understand how all the elements of a MWPP program can operate to form a comprehensive program
suited to the individual needs and resources of the State. The case studies are also included to provide
model elements which other States may be able to incorporate into their own State programs.
Exhibits following each case study provide even more detailed information on the State programs.
Exhibits include excerpts from the State administrative codes, examples of questionnaires and other
materials sent to POTWs, and examples of State data tracking reports.
-------
WISCONSIN
-------
WISCONSIN
PROGRAM OBJECTIVES
*
During the last decade in Wisconsin, billions of dollars in Federal (EPA Construction Grants),
State (the Wisconsin Fund Program), and local monies were spent to upgrade wastewater facilities to
achieve the water quality standards established in the 1972 Federal Clean Water ACL As a result of this
major sewerage system construction program, approximately 95% of Wisconsin's municipalities are now in
compliance with their Wisconsin Pollution Discharge Elimination System (WPDES) discharge permits.
However, it is not sufficient to merely construct adequate wastewater facilities; these facilities must be
operated and maintained in a manner that maximizes the design life of the facility. It is essential that
communities begin planning for system replacement or addition on a timely basis so that effluent limits do
not violate the State's water quality. It is also important for municipalities to have preventative programs
in place for all communities to maintain standards over the lifetime of their wastewater facilities.
To accomplish these goals, the Wisconsin Department of Natural Resources (WDNR) designed
and developed the Compliance Maintenance (CM) Program (Exhibit 1). The CM Program is intended to
protect the investment and to insure that action is taken before violations of permit limits and water
quality degradation occurs. The four major goals of the Wisconsin CM Program are:
to prevent violations of effluent discharge limits by municipal wastewater treatment
facilities;
to promote awareness of wastewater management responsibilities of elected municipal
officials by increasing their communication with wastewater treatment facility operators;
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to encourage and require, if necessary, municipalities to initiate operational improvements"
and design and construction of new or upgraded facilities before violations or the
resultant water quality degradation occurs; and
to maximize the useful life of municipal wastewater treatment facilities.
The most difficult obstacle in implementing CM in the State of Wisconsin was the public attitude
that wastewater treatment is a costly and messy problem. The capital cost of building a new sewage
treatment plant can be the largest expenditure that a municipality will face. Because these costs are often
unexpected and do not appear to increase property values within corporate boundaries, wastewater
treatment is a controversial, repugnant and certainly costly subject for elected officials to discuss. In order
for the CM to be implemented successfully, WDNR had to change public attitudes regarding municipal
wastewater treatment.
PUBLIC OUTREACH
By asking those to be regulated by the program to participate in building it, WDNR obtained
broad support for the concept and for the partnership it reflects. WDNR undertook a two year public
participation program which allowed all participants of the Compliance Maintenance Program the
opportunity to become comfortable with the program specifics before implementation. In 1985, the
WDNR conducted 22 workshops on the CM Program involving local environmental organizations :.
municipal officials, including elected officials, sewage treatment plant operators and public works
personnel. After the workshops introduced the program, four formal public hearings in 1986 addressed
the concerns or comments. Conclusions from the CM Program workshops included:
continuous planning to prevent violations is needed;
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depreciation accounts for upgrading of wastewater treatment facilities is needed;
the relationship of the CM Program to permitting is uncertain;
grants/loans should be made to non-violators; and
a technical advisory committee (TAG), represented by State and local officials, should be
appointed to develop CM Program.
In 1986, a 19-person TAC was formed from the regulated community to steer the program
initiative. This committee included wastewater operators, municipal officials, consulting engineers, an
environmental group member, a representative of the Department of Justice and WDNR staff members.
The TAC's objectives included refining the results of the public workshops, the codifying of a compliance
maintenance policy, and the recommending of a number of improvements to the wastewater treatment
program. The TAC developed a Compliance Maintenance Annual Report (CMAR) that all publicly-
owned treatment works (POTW) operators prepare and submit, through the local governing body, to the
State. Training sessions to instruct the operators on how to complete the CMARs were held in 1987.
This effort to keep the regulated public informed of the policy as it developed won widespread
support and acceptance of the CM Program.
COMPLIANCE MAINTENANCE PROGRAM DESIGN
The Compliance Maintenance Annual Report or CMAR is the cornerstone of the Wisconsin
Compliance Maintenance Program (Exhibit 2). The CMAR is a product of the Natural Resources Code
Chapter 208, which outlines the Compliance Maintenance Program. The purpose of this report is to
document "indicators" of future effluent violations. The CMAR is submitted annually by all municipalities
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and is used as a simple, objective analysis of their treatment system. The CMAR documents the
performance and condition of the wastewater'utility to WDNR, local government elected officials, and
operators.
The treatment plant operator completes the CMAR with the previous year's data and monitoring
information (i.e., 19W& POTW information will be 1990's CMAR) and forwards the completed CMAR to
the chair of the local governing board (the owner). The governing board reviews the completed CMAR
which the operator submitted.
The board, then, must pass a resolution documenting and acknowledging the review of the CMAR
and indicating the corrective actions, if any, that will be taken to prevent effluent violations. Proposed
actions should address areas where maximum or close to maximum points were generated in the CMAR.
This resolution should contain any other information the governing board deems necessary. After the
governing board's final action, the completed CMAR is returned to the operator with a resolution
attached. The operator, in turn, must submit the completed CMAR and accompanying resolution by
March 31 of the given year to the local WDNR District office.
The CMAR contains sections that objectively inquire about the condition, quality, and capacity of
the treatment system. The responses from these sections generate points in order to evaluate the system.
Other sections do not generate points but subjectively produce self-evaluative information regarding the
treatment system's financial status and operations. This subjective evaluation of the facility is intended to
inform elected officials of the ability of the wastewater treatment system to meet permit limits in the
future.
The CMAR's point total determines if the municipality should begin extensive planning and
construction of new facilities, modify existing systems to avoid effluent violations, or undertake no
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correctional activities. The higher the number of points generated, the more likely the community should
begin evaluating their system to determine the improvements that are necessary to prevent effluent
violations. The maximum point total is 400 points. Points are generated for the following treatment
characteristics:
effluent quality and plant performance [0-100], an important indicator of the efficiency of
the facility in regard to water quality,
influent flow and BOD (biochemical oxygen demand) loading in comparison to design [0-
80], indicator of volume and amount of wastes entering wastewater system;
age [0-40], another probable indicator of the efficiency of the treatment facility,
bypass and overflow occurrences [0-50], an indicator related to efficient design of overall
wastewater system;
anticipated community growth [0-20], an important indicator for future planning and
design;
sludge storage and disposal capacity [0-100], a good indicator of the design efficiency of
the system; and
operator certification and education [0-20], an important indicator about the level of
formal training in treatment processes.
-------
The point total corresponds with response levels, at which certain actions need to be taken. The
owner may submit an explanation of the assumptions that were used in rating the items and determining
point values contained in the completed CMAR.
The following are the ranges and point totals that indicate the actions to be taken: 1) Voluntary
Range; 2) Departmental Recommendation Range; and 3) Departmental Action Range. In the Voluntary
Ranee (0-70), the owner evaluates and implements tasks voluntarily to correct the identified problems in
the CMAR, if any. The owner may initiate longer range planning for new, upgraded, or additional
treatment facilities. In the Departmental Recommendation Range (71-120), the WDNR notifies the owner
of the treatment facility that an operation and needs review (ONR) is recommended. An ONR evaluates
the treatment system's ability to maintain effluent limits over the next five years, focusing on specific
problem area(s) and offers solutions to those problems. If the problem is serious, that is, if the CMAR
indicates that the existing system is not capable of providing adequate wastewater treatment in the next
five years, a facility plan is then also recommended. The scope of a facility plan is based on individual
point totals for each information item identified in the ONR and usually requires that a workplan be
submitted.
In the Departmental Action Range (121-400), the wastewater facility owner is required to
complete an ONR within a certain time period prescribed by WDNR. Pan of the ONR will consist of a
workplan that lists all necessary actions and time schedules for the treatment system to maintain effluent
limits. A facility plan may be required if WDNR determines that consistent future compliance with
effluent limitations will not result from improved system operation, maintenance, and efficiency or that
growth within areas served by the owner's sewerage system jeopardizes future compliance. If necessary,
WDNR may modify the owner's WPDES permit to require one or more of the above reports.
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ENFORCEMENT
In the past, municipalities that violated wastewater treatment standards received the greatest
attention from regulators, and enforcement actions were taken only after the laws were violated. Previous
State and Federal regulations clearly sent a message to the municipality to take action only after the
problem occurred. Most State regulators, community leaders and wastewater operators were comfortable
with this approach. During the 1970's and early 1980's, the existing regulations and grant programs
brought many municipalities into conformance with their permits. However, this policy contained little
incentive to maintain permit compliance. Therefore, a major objective of the public participation program
was to convince the participants in the present system to change their thinking to a more preventive
approach. The CM Program is different from other programs in that it completely shifts Wisconsin's
wastewater management program from a reactive approach to a proactive one. CM requires municipalities
to continuously evaluate their system capability and begin formal planning, design, and construction to
prevent violations and associated enforcement actions. Also, a State task force had made a preliminary
recommendation that Wisconsin's state revolving fund award first priority to municipalities that act before
violations occur. The idea to make grantsAoans available to non-violators was an important
recommendation from the CM workshops.
In the past, Wisconsin only awarded construction grants to those facilities in violation of the Clean
Water ACL The U.S. EPA construction grant program is phasing out, therefore, Wisconsin is beginning its
first year (1990) of adopting a low interest loan program for the funding of their wastewater treatment
facilities. This innovative funding feature rewards facilities that maintain good compliance records with
reduced interest loans. Wisconsin is incorporating two unique provisions for low interest loans to facilities
that have a non-compliant status. The first provision provides low interest loans to facilities with
economic hardships. This provision involves increasing the funding available to a facility based on a
financial trigger point that decides the optimum interest rate of the loan to the facility. This interest rate
-------
of the loan can be as low as zero percent. Also under this provision, the WDNR is permitted to transfer "
available funds into grant money that can result in the facility receiving up to 90% of the funding required
for necessary improvements.
The other unique provision in Wisconsin's low interest loan program is to provide for unexpected
events or occurrences that are beyond control of the facility's standard operation such as weather-related
events or mechanical failure. However, the availability of a low interest loan in this provision is closely
associated with the facility's recent CMAR recommendations made by the WDNR.
Involvement in the CM Program does not shield a facility or municipality from enforcement
actions by WDNR; however, more concentration is placed on gross or substantial violations. Most facility
violations are not addressed through the CM Program, but instead through the State's existing permit
actions or enforcement program. The owners (i.e., the municipal board or utility board which governs
POTWs or the management board which governs a private treatment system) must review the CMAR and
formulate any necessary corrective actions to solve any shortcomings of the system. Failure of the
operator-in-charge to complete and submit a CMAR may result in a maximum forfeiture of $10,000 per
day of violation. Failure of the municipality to file a CMAR could result in a $15,000 penalty for the
municipality in which the facility is located. Such fines encourage treatment plant owners and elected
officials to become involved with the issues faced by POTW operators.
RESOURCE INFORMATION
Initially, Federal, State, and local monies were spent to upgrade the wastewater facilities in
Wisconsin. And while available money for facility upgrades has been decreasing, water resources are a
high priority in Wisconsin and receive a great deal of support from elected officials. Elected officials have
supported the idea of CM funding coming from an environmental fee program, which requires each
8
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discharge permit holder in the State to pay a fee to support WDNR. The WDNR also received partial
budgetary assistance from EPA for initiation of the Program through funding provided under Section 106
of the Clean Water Act.
Normally, there are over 100 FTEs to implement wastewater programs throughout the State.
However, the first year of the CM Program required six to seven additional FTEs, although this figure is
declining over time. The CM Program does require, for actual maintenance, approximately three FTEs at
each field office (6 District offices and IS Area offices), which are funded under the State permit fee.
PROGRAM MANAGEMENT
The WDNR manages the CM Program for approximately 650 municipalities throughout
Wisconsin. WDNR staff and Area Engineers provide technical assistance to the facilities. They also
conduct inspections and carry out any enforcement actions. The strong management system and the good
field staff have both contributed to the success of the program. The CM Program has become a means of
enhancing communications. Its an early warning system for the operators as well as the regulators.
The WDNR has always tracked loadings, but the CMAR puts data in an accessible format and
creates a forum for review. In the interest of maintaining and improving open communication with the
operators, WDNR wanted to convey the importance of the point totals. Therefore, every year a statewide
summary of CMAR point data for all municipalities is published (Exhibit 3). This summary is considered
public information for all communities to inspect. WDNR has begun to utilize the data from the summary
to try to plot trends within a given community. WDNR will track changes over time for each community
in the State to see if compliance with the CM Program is improving the ability of each municipality to
meet water quality standards.
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In conclusion, the CM Program provides municipal officials with an early warning system for
evaluating their plant's capabilities. The wastewater operator completes the annual report on the facility
which is then passed to elected officials prior to submittal to the WDNR. This approach to government is
unique. CM does not wait for problems to manifest themselves, but influences municipalities to act as
partners with the State in the protection of water quality.
For more information on Wisconsin's Compliance Maintenance Program, contact:
Mr. Chuck Barney
Program Manager
(608)266-2304
10
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EXHIBIT 1
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DEPARTMENT OF NATURAL RESOURCES
«
Chaattr NR 201
COMPLIANCE MAINTENANCE
Nl ttJI Pirpat This ehaotar imotonmu eh. 147. g»i*« aad ta-
cooftfaiaad. »lur« Maoary. rwqwraowMnaf publicly owwa tmc-
ami worn tad prmuly owmd demonic atvtft traunnt woru to
ttfcf BMaawy aetioM to avoid wiur quaittv d«frM»uaa ADA errrtnt
v«tuio« o< WPOES pcnnn tfliMac tifluu. Thto
tjMi wiiieh erMBdU the OWTMT a wifUKaiifld rapoaafa
rdr. «flpam fi*mrt. tan. N*. fit. 4.M4T.
Nl 20M1 AiUalilliy. Thii ehaotar tootfe* co
a tnauDBM omaaa pnrauiy OWMQ OOBMB
Cr. IU«M. Urmn. l«f. N« JT4,««.
Nl »m Dtlrtii , la
ia eta. NR 110.114.20S. 2M «M 210. AM ea. 147. SUtt. ta« (oUowiac
i *0Mr to unn a tAa CBAOMT.
(I) TnatHjim ii«ftMM» anari noon" or -CUAA
ffpBK VhHfe IB* CVMT Of * CTMUBMt VOTfei MMM
ro iMiiin fhi niniiil mrtlilnM < Itii »«fiaiiiia<« irf ilx nir i
(2) -faottty paw" aaaai a raoori wkka th* OVMT of a tmuntat
*rta aaaaita to taa itonaiiimai taat rngian of ttaoi aMayy puaa
tnatatai faolitm or addttioaa to nauaf arvtfi crauaMat fioJiiua
'I
j3>*0pmtipaiadi
»oiiityoitafli
(41 "W«k ate" aaua a ail of all i
) tat ttatfty ptaa «r
-------
WISCONSIN ADMINISTRATIVE CODE
cr a mart dtui tv»iu«iion of tht wwtnn iv*.
tm SMU bt eonducttd. Tht owntr nut ihtiSJwifSt «3u£ SI
CMAR to idtmify *»* lor (uturt olaamnt ^SonTln^iStioI
itdt point ntmt jyiwtn. tht CMARsJuil (tturmint whethwuwMl
systttn owiwn Mill mituu aeuoiu to.prtrtat «fflurat urait
12) SUBMITTAi, TIMING AND OTWER MQVfUEUBMm Tht CMAR shaU
the CMAR shall bt suhamttdi to^th^eanmtaToa watfort ManaSi
of catft subatdutat ytar. Tht CMAR shall bt bastd oa ta/ormauoa aad
moaitonai data eoUtcud IB tht BTOTOUI ealtadar yav. A duly autho-
na«d rrpnantauvt of tht owntr shall compJtu aad s«a tht CMAR.
(3) RooumoN. la tat east of a aaettdy own* tmmwt wwts. a
rajotuiiun iron tht muaaaoality's fortranf body shall aetooaaay tht
CMAR. Tht Motetiaa hall iadu£TtteJdtiS 7
lai Aa ackaowitdftatat that tht |0»«aiM body hat umiml tht
CHAR:
(b» A dwcnoooa of aetioot whkh tht OVMT Witt ukt to
to Aay other tafonBacioa tht towvtac body
(4) CONTWT. Tht CMAR shall bt submitttd oa fom§ imiidtd by
tht dtvaruatac. Tht owaor saaii suopty aad aaatyw tht loikma« la/or-
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DEPARTMENT OF NATURAL RESOURCES^ ^ S-3
(2) RATUNB rrao. On IB anauai baia. tht owner inaU cakuaM a
MUM toui T whiea a OUM on uuorraauoa orvndtd by tnt ewiwr in tnt
CMAB- Tbt petal IAUA T ***" M (Mwmavo wtia l&t following tqua*
TQ « TBOO * TTSS * TACE * TBYP * TBEF
* TND * TFD * TOC » TOT1 » e.Q whica a o«4ata
T -
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2-4 WISCO NSI K ,\ D M ! N ISTRATIVE C*0 0 E
Ktrrmtoar* «f Pmrtucn
CafeiMir tear
Numbtf of Montta that A Prrctm of BOOi Cflurat Limit
tht BOOi Eflutnt
90% 100%
0
1
2
3
4
Sartnaur
0
0
10
20
30
40
0
5
S
10
10
10
TTSS. tht peat MB ratettef to tht tOutat Umit (or tool:
aoiids. ihaU tooal tht wn of aimbon ippauini 10 Tablt 4 (or
Moi o( 90s/. and 100% of tht noaUly avortft tfliMM Jimiu eoa-
UIMO 01 UM WFDGS permit. la tht tftonet of omitUy a«wm«t efiont
liani (or total mipindtd »aiida> tiiy tflunt Umiu thiU M toM ta
tho eakalauoa. If no total imoudid »Mi Unit iadudoi ta tat
WPDCS ponaic TTSS shall tquai 0.
TaWt4
of tatToiai 3 ttt SdUt ttatw Ua*O) to tat
Yaw
o(Moathtthata PwaatafTSS
thtTSSCBotat
Uawisi a CnaMtri 10% 100H
0 00
i 0 S
2 US
3 21 10
4 31 10
Sororauar 40 10
rot TACC. tht POOR mm rvfetiaf to faoBtr ata. atoU to tht tat *
wMatattTftof
TAGtlawi
U
U
10
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DEPARTMENT OF NATURAL RESOURCES^ ^ 2-5
, n TBYP. tht point urn rtiatiAf to bypaauc out to ortciottation.
shall bt tM numotr o< catenoar nays mat oypaaats or ovtnlowi aut to
Dnapitauoa tvtnu occurrva durint inr ortvwui cuuouar yw muiu-
putd by 6. Uadtr tnu suaatttton TBYP may not ot frour nun ^i.
t) T8EP. tht poiat turn rtkatiac to bypaauac due to tquipmtni (ail-
ura"iaail ot UM numeor o< cakaoar oayi'taat byvaaMi < ovwrdow* out
to MuionMi liiiurt oeeurrM dunni int ortvwua caicr. -*f ytar mmti-
piM« by S. Uadar taa suoatetien TBEF may not ot frour UUA iS.
(hi TSTC. tht ootat total aaweiaud with siudft normft eaoaeity.
ihAii bt tht aumov o< poiau aoptanaf oa TibJt 6 niauaf to uit aiuoft
uonct capacity of tat owntr > wiauwattr trtttmtat (aniity ana ot
at*, r or atnttd lacooaa aaa sueUixauoa oonoa. TSTC shall Muai 0.
20
thai or auai to 2
LAB taaa 4 noataa but war 10
thai or total ta 3 BOBIM
Grauor taaa or tqvai ta> 4 BMatha 0
fll Tm lln iniial Mini mill ilili iluilii ilimnail litai ihill tii
itedft dipaoaai artai apawwd (or vat by tho ponaMta. For aorattd
laojaoaa aad itahiHntma eoada. T8D shall tmal 0. for otaor (aolnita
that oo aat diaeairit atud«t o» iaad. TSD shall to^al 0.
TaaioT
vita 9adft Ottaooai Pracunt
NojabtroiMMtteTb*
Panantot Haa AOBJBI M
aad ApprovBl Cor SuaVaaat
PobM Total
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24 ^ WISCONSIN ADMINISTRATIVE CODE
tfl tht *"*"* » ***r*V system. Othtnrot TND shall
ik» TFD. tht poiat total aaociattd with futurt dcvtMomtnt within
gww «nrie» am. shall vquai 10 peinu it MW tovttoomtM a liktly
ptrmnut i M*trat* sysum. Othtnmt TFO Uull t«uu 0.
°C lh°t «i««^ w«h oMnur ctniaauon. shall
tht oouu total]
laiia
u eonoitttd trauor thaa or tqval to 12 houn of
jag tduouaa ia tht arwnoui 2 cateadar ytan. TOT shall tonal S
poumrf tht chid owrawju.eomcttudta.uaa 12 houn o<
iRf tdueauoa n UM artnoui 2 ' '
(ailCa tht (actor thai tquallM tht poiat mm (or diffcmi trpoi of
tnatmmi pteats. shall bt tqual to IJA (or aaraud lataoaa ahd
oemti that dteharnT^a^wZfClMWSSi
aaa MaatuatiM aoads that diaehafft to troaadwatir. U4 (or
(J) CAicuutiow or CMAft poor? TOTAL, Tha CMAR shall taetado
tht araiadan (or tiUniattai tht aouu teui of tht tuiaa « Mhw (»1« Tba
~ -
i MUH to
OUR i
of UM saaiBiiiinai that »in uisd hi nta* tht itttaa
iatht(
* IMUBaW* aMMMHa^o WaWi 9*9* aTT'fc flaw vVvdWii
Ni MJI itfto* «r CMAJL (li DVAamajir um»
AI«, Tht ONartBMat ahail rtrMw tho CMAft aad tat ooou total OBB-
taawd ia tht CMAft (or aaiBricf aad HMIHIJUIIBBI Tht atparuntat
shall aottfy tht owmor withal 40 day* of aohwttal vlMthar tht CMAR
" tht oouu total ritmhtmiiB art iuoiullt. la cap «(tmr, tht o>»
i snail tvoBJaalatB ^*tr aoiajt total aad aotMy **** OVBBT at ****
ItauhvTlMi ' " * '
aJBBjarf raafi. for aasat totaliooBal to tr >a» thaa 71. tht owaar
tfihaCMAA
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DEPARTMENT OF NATURAL RESOURCES - 3.7
"»'
indicate int tiotinf jynrai a not casaeit o< pnmdiac aatQuau wt*»
»»ur irtauntni in int nttt 5 ynn.
ic) Otsanmmi aawn ran*. For point totals cmur than 200 (or ait
CMAR'j suofflituo ounuaat to tht Juat 30. 1917 tftaohnt. tot moan*
mtat laaii nauirt int owntr to«ampmtt aa opmuea «ao nt«a* rtvww
witiua a uat otneo wntea tht dcoarxatoi crvcnem rhnmur. tnt
dtovtmtat aeuoa raaft mill bt cmur taia 120 DOIIU. A (tetiitr piaa
Jh*il bt rtqoma if tht Ateanmtnt dtunauMi uat eeaiount (utun
nMnninnct viu tamat luniuuona mil ooi ramt (rm imortinu jyv
traoptnuoo maiMmucB aad iflritmr or that pvwta wttjua amt
*'T>* bf tat ownor s «vtra«t wrntm jtopvttOB
WFOES pcram to raquvt oao or wen oi tao raitmeM rvoaru. All pr^
i U3ta ia tat aoaiAcaiaea at a W?OE8 pranaaaii eoaiora wit*
iiaea.NR203.
saaM bt baan OB tadmdoai pout totatt far
ia a. NR 20US (2). TIM ONR atatt
mum to
th* tavta iaotifc7 vUi
ana. Tte ONR may
a (aoiitr piaa (or
(flap*
<«) IrYrt pin. T»* O^MT taafl aafcort a work plaa ai a part of tte
(aoiity piaaer tat ON R. for a omiv«poj»4iaf pravw. tat f«ri o»aa
tell bo a asavoxlo ol all aooafiawy ptaajuot. do
taafea (or tat at* tjmuom, Work piaao aur al» i
CaCAU oooj aot prKhidt tat ot-
«na da. A 38. JL144 «M 14T. Stata,
^)MniioiioF»oarfTAUi».
,(2L
afcoilo*
.lOJI.lta.ITI
-------
WISCONSIN ADMINISTRATIVE CODE
**
< e I Sevan tmtmtnt plant oocnion:
(d) The attoraty ftaorai: aad
(i
Ni M.I7 A«taMn««n4 M MMUM na»tiMMt. 11) RCfOtTSVIMir.
TAI. UQUiUMUm. AU (aeiiitjr pun of epvMioa «ad MMi rrotvi
itell b* wMucud to UM tf*ovtm«it on a uatiy taap. for weikiy
I imUMM vorio. a rtsateuo* paavrt by UM nuaieioaiity's fpr>
Ihirty ihill iffuminijr ihafniliii pm nr ihi nmiinni inrt i
(at Aa
to
that tat forarntftf body baa
tat
(bl
cht f§fi*i*y piaa of
tat work ptaa wliitb b)«oataia«l ia tttaar
%n^ attda rwwv. airt doacnotjoa of ac*
take to auiataia ooatptiaMi vitfe ofluoat
<«)!(
to bo «ad to imaa>>
Tao doaafuaoaft otty allow addi*
tbtjpvt OBML fajiafi tbat tbo dUanaioii
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DEPARTMENT OF NATURAL RESOURCES ^ ^ C-9
S) WPDES PCXMIT. The dtovtmtat BUT taia action ta moai/y tht
owner s WPDES permit ta tneiuot tne wort otatt or suomutnt or i
ivy rmaoas to mamuui eomoioae* witA tfflucat limitations.
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EXHIBIT 2
-------
Compliance Maintenance Annual Report
P«nie
Ptraic Nuab«r:
N«M «nd Title of Person Coapltcing Fora:
D«c« Ce«pl«e«d:
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COMPLIANCE MAINTENANCE ANNUAL REPORTS
Information Source List
You will need the following information to coaplete your coapliance
maintenance report which covers calendar year 1988 (due by March 31. 1989).
Part 1 a. The average plant influent flow for each month (million gallons
per day) in 1988.
b. The average plant influent BOD for each month (ag/1 and Ib/dav)
in 1988.
c. Your plant's average design flow (MOD) and design BOD loading
(Ibs/day).
Part 2 a. The aonthly average effluent BOD and TSS in ag/1 for 1988.
b. Your VPDES permit effluent limits for BOD and TSS in ag/1 for
1988.
Part 3 The age of your treatment plane defined as the number of years
since the last major reconstruction to increase the organic or
hydraulic capacity of the plane. The last calendar year (1988)
minus the year the now construction was brought on*line.
Part 4 Bypass and overflow information. This is the number of days in
all of 1988 whan chare was a bypass or overflow of untreated
vaatewater duo to heavy rain or snow molt, or due to equipment
failure whether intentional or inadvertent from all collection
systems tributary to this treatment facility.
Part S If you landspread sludge, hew many months of sludge storage
does your plane have? This should include on-site and off-site
storage from the treatment plane. The digeseor capacity may be
used ia the calculation.
Part 6 How many approved land disposal sitos for sludge do you have?
How many months or years will those bo available for use?
Pare 7 The number of sowar extensions which wore installed in your
cosMuniey Iaae yoar. You need eo get the design population.
dasiga flow and design BOO for each sowar extension from your
engineer.
Part 9 The beginning (January 1, 198S) and the ending (December 31,
1911) balance of your plane's segregated equipment replaceaent
fund. If this isn't available from the Treasurer, use 1987
data.
-------
State of Wisconsin
MAINTENANCE ANNUAL REPORT
Department of Natural Resources
COttPLlANCi-
Chapter NR 208. Uls. Ada. Code
Fora 3400*130 tuv.
Inserueeions co the Operator-in-Charge
1. Complete all i«ccions of the CHAR, to the beat of your ability.
2. Psrcs I through 8 contain questions for which points will b« generated.
These points art intended to communicate to the D«partm«nt and the
governing body or owner what actions will be necessary co prevent effluent
violations. Place the point totals from parts 1 through 8 on Pag* 10. the
Point Calculation page.
3. Add up the point totals on pag« 10 and oultiply by th« correction factor
indicated.
4. Submit the CHAR to the governing body or owner for their review and
approval.
S. The governing body must pass a resolution which contains the following
points. A private owner should address the following points in a letter.
a. The resolution or letter must acknowledge the governing body or owner
has reviewed the CMAt.
b. The resolution or letter must Indicate what actions, if any. will be
taken to prevent effluent violations. Proposed actions should address
where ^+«1""* or close to « points were generated in the CHAR.
c. The reeolutioa or letter should provide say other Information the
governing body or owner deems appropriate.
6. The CMftJL sad the resolution or letter should be submitted or mailed by
March 31. 1919 to the Ml Plaeriee afflee listed on the letter which is
attached to this report.
Completion of this form is mandatory. Failure to complete end submit this
form may result in a maxiswm forfeiture of 910,000 per day of violation
pursuance to s. 147.21(2). tfis. Stats.
-------
ort 1;
A. Hit tta mmrtft ontftly vol_»tr1c flow ond MDj lotdlno* rocoivcd it your focUlty o_rin| tn« t«*t
colon* VMT.
Col. 1 Col. 2 coi. !
nontftty Mw (CD) Av«raf«
(UUen ilora) Conetntrition IGQ i
Kerch
April
July
MD$ loMInf *nrm Mntftly Urn On ) *»trm Mntkly HDS e«K«nr«t4«n «n MI/I) i 8.34.
I. List tlM nirni «M««n flw anri o^roto «<* MB, iMriln* f«r ymr fwdltv In tn« DHr*i MIM. If vou «
l 8 P»tnt«> ! 10 »i«nttj S or mn 1$ point*
I. *» m* tta-i «U tta «omfcly Wo. iMhHm (CM. S) t» tta -fl»
(Clrtlt tta tjprojrtm IU*H>>
-------
Fscillty MBit
f. MM ow tlsao d«« tlM oontMy MO) ioodino; (Col. 3) to tho wwr» *MM« CM dosion
(Circls tM spproprists
0*0 points; 1 to points; 2 20 paint*; 3 SO points; 4 40 points;
S or o»ro SO points
6. Md totttnor ooch point wttuo you circles) f«r C ttirouin f onrt Discs tnls sui In t*s btsnk MIC
C p»«"tt ,^M«___-
0 points __, mmmm^m _
I points .^___
f points ^ g^ i^._
TOT»L »OIIIT VM.M >0i WUIT 1 _^M
Intsr tnis «oiuo on tl* 'otcuUtitn pops st tho book < tM CMM, poos 10.
^t au.iitvynmt Mi-fan
A. list tho sKsrojo oontnty tffluont MDj onri Ttt esmontfstisn produeos) by your fseUtty during tn« tsst c«i«r«u
ts»/n TM tusvi)
I. Hit t»» softly WOTS* pwvjlt Usrltt fw tm »s«Ultv «« « «i«*o *oi«. If s»M>tv svysts Us.its «r.
csmainori In «w »w«t. IM tto wdkiv twrswi l««t« in tM P»rsrtt. If « lapsiMd solids ii-it siuti.
tout s»lm» for «>Mt1«« I onsl 9 «m osvii toro.
T« c»«/u
Mi * tM Nralt Usrftt
-------
'ctUty
C. MM -*»* OBW&« did tho offluorrt Mbj coneontrotion oscood 90* of ponit liaittt
(Ctn--s tM «apropr«m
0-1 o o points; 2 10 paints; J 20 points; * 30 points; S or OBTO 40 points
0. NOW o«ny Months did two offluont PODj eoneontrotion «*cood ponMt liMttsf
(Ctrelo tno mprnjirtsTi
0*0 points; 1-2 5 points; 3 or o*r« 10 points
I. MOM MOT* Months did tno offluont Tit concomrotion oicood 90S of psrait Kaits?
(Ctrctt tM uprsaristt
0-1 0 points; 2 10 points; ) 20 points; 4 10 points; S or pert 40 points
f. MM onv oamns did tho offlusm TM eoneontrotion sitssd ponrit liaitsT
(Cireto tno opproprioto nuoaor)
0*0 points; 1*2 S points; S or oar* 10 points
6. Add Men point votuo eirelod for C tnrouoli t ond ploeo in tno blonk bolMt
C points .^.^_^__-.
0 points ^ mmm^ mm
I points -
r points ^ _ _
TOT41 WI«T VAIUI rW. Mil I _ _
Intor ttiis total on tn« soleulotion ppojo st ths task of tns CMM, pkfo 10.
»srt S: *«o of tno MootOMOtor Tnstoani
*. Mhst yodr MO tut MStoMtor troptaom piont eomtrustod or loot rocomtrgctodT
Subtroet tno ofeo«* onoxor fros> IfH to dotonino *po<
too (lost eslondor ywr) (AMMOT to A.)
< 1
Intor Afo in Port C., OOIOH.
I. duct tM typo «f trosMsnt fooillty tMt Is
Trootaont Horn or 2.0
It T«k/Mnd mtdr
1.S
ttoftUlntion
C. ftrttlpiy tfco fpxtar Ustod non to ttw tw» » f«Ulw row o-wiity «p»iov« kv tno oo* of
fptUlty M «MvalM ttw MMi po«"t sow* «!« «dr Nrt li
TOT41 MIIT
VAUJI rot C
MT I
If tho point totol oMoods 40 points, OJIMT «Mv 40 fdr tM Nrt J tpt.l on poo* 10. Otnomiso, «itor
tM sow* Mlw on tM coldwiotlon pos» ot tM task « tM GMI, pooo 10.
4
-------
facility
In MM lost yeor MO tnoro t oyooos or overflow of witroatod MOtowotor Out to now
0 0 ooinn: 1 5 points; 2 10 points; J U points; 4 20 points;
5 or vero IS points
I. NO* o*ny days In the lost yoor MO there s ovaees or overflow of unrooted MStoMtor duo to tquipwt
tsilure? _____ (Clreto One)
0*0 points; 1 S points; 2 10 points; S 13 points; 4 20 points;
S or OBTO 29 points
C. Specify whether the bypossoo COM fr*» th* city or villa** saner systsa «r f^v eontrset or tributary
titios/sonitsry districts, otc.
0. Add tototMf oscfl point volgs circUrt In A ond I on* ptoco In tho Monk bolwt
TOTAL POINT v*iui t9 'UT 4 .^^ ^^
Intor tnis votuo on tno cotcuiotlon pop* st tno bock of tho OMI,
10.
If your MootOHOtor t
plant
ontM of sludpo storoto
aifslto or off-sltot (t.o.. MOM
tudojoT)
^______^__ (Clrclo tho ojprofHoto point totol.))
, 90 on to Nrt 7.
ity dooo your MOtOMOtor/trooaojm fosillty n«v« ovoiloBlo, tltnor
con your fosility oporoto ulthout ISMSproodlni or dlsposini
Grootor than or oawol to 4
LOOS than 4 aontM, out frootar than or oswol to S
Loss than S aamho, sue trootor than or oavpi to 2 aanths
LOSS than 2 aamtM. but aroatar than or oovat to 1
LOSS than an*
0 point*
10 point*
20 pbints
30 point*
M p*int*
TOTAL Wilt VALtf KM T J ^
Intor tni* «*ius an c*tcul*tlan
*t tho fe**k of th* CMM,
10.
f*rt (C1r*l* flw
CM SPBTOWI f*r) *uff1*1«nt tin* *H*B*Ml site* t* provide proper land
p*lnt t*ul).
lor oar* ye
12-0**ntt
l*M «HJI4
ot p*«m»;
II p*int»;
TOTAL POIIT YJUIB Ni
Inter thi* *its» *n aw **i*ui*ttan
t th*
^^ ^BkA iVJIMpl OB^^HK 4*1
f tM MHff p*%li "
-------
facility
A. 'loos* provtds the follOMino; inforaotion for tU MMT utonoiano tftich «oro Inatallod durin« tn« i«»<
call
Ooolpn Populations __ Ooolpn Flan _____'0«l»n «CDS:
I. NM on industry of tno oporotor- in-ol*orps on Mnutry 1, 1
I. ttiot is his/nor eortifleptlon
C. whot «ropp of oporotor H*ur* ** o*miniim oduntlon koo tno opsrotor in»ofc*fo* e**M«t*d ovor tno loot 2 (two)
(C1r*lo Om)
11 fedHT* or **r* o o point*
IS kdura S point*
A. tm tsurtir «*** d*«m «*luo v*v olrolod In I *nd f ond pipe* tHls su* in tno ftl*nt tolOM.
TOTAi-pOldT WUdJ Mi MMT I ._
Intor ail* vdlu* *n a*loul*t1*n ppp* ot tno Ms* *f tno OMft, psd* 10.
-------
'Cititv
A. Art Uoor*Cnor9o lovoruoo gfflelont to eor oporotion «w «int«w«et MponMof if f», no* «r« at*
cooto
I. louipaont tootocoBint >»** 00 TO MIT C, If you did ggl ''e«<*« Mdeomin n«i* or (>A
Grant for tl» MHT vftttm nd/tr trMtwnt piwt.
A Mfr«wtrt quIfBvn nelMMm ftfld U r««ilr«d If Witctntln f*M grant or f«atri( »i 92-500
grim M» r«c««««d f«r tn«u»n fwitlty cmtnmtm. nita Met1«n w§t e> co»t«tM dv «u tuen
grwt r«e«t<«ntt. Tour runarm vr to uMrt to dttorvlno eoNptiarc* with th« roptoctMnt
*ro ttM rcpiwoJHnt findi »nT foeiKty:
I. OoatHto d» condition of tta OOHOT tyttom (clov wotor Imruoton. lift ototlono)
-------
'ciifty
C. t*iot nuirin tyotoi iojiri' OMIII oooo th« e«M TOO M
4. Ar« thooo prmvitttlvt PBlnMram* tMka. «P wil « «*rip««« »«*. "«" roeorw* wri flirt M
futtro IntonMO promo* cv» o» oooMod proporlyt (Ctrelo Qno) TO* M
-------
'eility >: ^^________
IMt tM
L. Utat p»t4«i «f tlM cantirwin*'«duution tiamM of th« ao«ritor-tn-eft«rtt MT« paid f9r By tn«
_ ly tiw «Mr«t«rt ....
H. It tfi«r« «r
-------
Ulty
Mint Calculation »ooo
1. mi In the valuoa ffOH ports 1 through in MM col
oolOM. MM tfta nuoMf* in th« i*f<
dotoraiino tho OIM point total that tut aMtOHotar tyato* AM oonoratw for tho prtviM cn
to
y»»r.
rt 1
2
J
rt S
rt t
rt 7
rt I
TOTAL
, points
, point*
point*
.point*
.point*
point*
.point*
point*
.point*
0 point*
' 1M point*
40 point*
SO point*
SO point*
SO palm*
20 point*
10 point*
400 point*
2. Clrcio tno facility typo that boot daocriboo your plant'* troonont and diapooal of tho Mastavattrt:
Multiplication
Nochanieol plant with ourfood voter oiacnaroo 1.00
Aorotod loddan or tafetllsation pond or aoptic tank/sand filter
ith surface Motor diocftareo 1.3J
Mecnanicel plant u*in* land diapoool of lioytd Mate* 1.14
Aorotod idfodn or (toBiliutten pond or septic tank/aand filter
uainf land dlepooal of liquid eeetee 1.M
3. Multiply tho total point* fre» «metl*n «1 ev the OMltlplicotiar, fecter
you circled in ojuwtien ft. This I* your (captions* ointenonce point total.
Total fro*
uitipt teattan
0 TOptd.
n iao pt*.
121 400 PC*.
voluntary
4. in duootiora 9\, d» any
f tno point wluo* in tta loft eoluw oval
portioutor o>mtiont (Clroto Ono)
tlio doilBM (riejit eoluvt) that
TO*
9. If «H «wv t« «Mtion 4 i« yod, prowido witton owianotian for tfti* aituatian in tno apoco boim
10
-------
COMPLIANCE MAINTENANCE RESOLUTION
RESOLVED chat che (City), (Village) of
informs ehe Department of Natural Resources that the following actions w«re
taken by (governing body) .
1. Reviewed che Compliance Maintenance Annual Report which is attached co
this resolution.
2. Set forth che following actions necessary to maintain effluent
requirements contained in the VPOES Permit:
(*)
(b)
(d)
Passed by s {mAigClCZlil<tifJBUftl vote of the
on (date).
Clerk
11
-------
EXHIBITS
-------
CGMPUANCE MAINIF.NANCE ANNU/U REPORt
31011
6085?
60895
?6191
30970
22047
20001
?1636
60071
32140
??<62
71938
60089
29611
2)078
37018
3U02
258*4
40066
60470
60721
26701
60305
29416
60267
30449
34665
36153
61085
31887
60356
2934]
31879
30856
30864
MCII IIT MANE
WHEAIIANO MORIIE HOHE PARK
UHEEIFR VIU OF
WHIIE IMC. vtii or
UHIIEMSH BUT VIUAGF. or
WHI1EHAU. CUT OF
WHHEIAV UASIEVATER TREAtMENt PIANT
UHIIEUAIER UAStEWAIER TREATMENT PI ANT
WHITING SEWAGE TREATMENT PIANT
WHO ROSE. VIllACE OF
WHSON SEUER UlllIM
WIL1ON WASIEWAIE* TREATMENT PIANT
WINNECONNE SEWAGE TREATMENT PtANT
WINTER VIUAGF OF
WIS ACAOEMT
WIS AIR NATIONAl GUARD
WIS CORP OF SEVENTH OAT ADVENT -GO SEEK
WIS DEUS-tAKE OEtTON SEW COMM
WIS RAPIDS SEWAGE TREATMENT PIANT
WIS STATE DNSS FLAMBEAU STATE CAMP
WIS STATE DNSS FOX IAKE CORR INST
WIS STATE OHSS-KETUE MORRAINE COR INST
WIS STATE DNSS LINCOLN HIllS SCHOOL
WIS SIAIE DNSS-MCNAUGNION CAMP
WIS STATE DNSS-SO W|S COIONT-TR SCNOOt
WIS STATE DHSS-WIS SCHOOt FOR ROTS
WIS STATE ON* COPPER FAUS SI PARK
WIS STATE OUR PATTISON ST PARK
WIS STATE DN* PIKE IAKE SI PARR
WIS SIAIE OHI-ilOE MOUNDS ST PARK
WIS SIAIE DNR-80NG RECREATION AREA
WIS STATE DNR- LONG LAKE REC AREA
WIS STATE Om-PENINSUlA ST PARK
WIS SIAIE ONR-YEUOWSTONE tAKE SI PARK
WIS SIAIE DOT -EAST TROT REST AREA 36
WIS STATE DOT-KENOSNA REST AREA 26
DIST.
SE
we
NC
SE
we
IN
SE
NC
IN
we
we
IN
NW
so
NC
SO
SO
NC
NW
SO
SE
NC
NC
SE
SE
NW
NW
SE
SO
SE
SE
IM
SO
SE
SE
DESIGN
FtOW
0.0390
0.0250
0.0500
1.2000
0.1000
3.6500
0.3100
0.0900
0.0240
0.0900
0.4950
0.0500
0.0340
0.1270
0.1000
2.8300
4.0000
0.0100
0.0900
0.0600
0.2400
0.4450
0.0500
0.0189
0.0250
0.0020
0.1330
0.0100
0.0400
0.0014
0.0180
0.0100
TOIAl
POINTS
49
T79
19
0
55
95
30
12
227
15
116
T9
6
115
33
16
68
196
33
248
165
0
266
78
44
53
34
0
20
29
27
93
34
102
0
PART 1
POINTS
to
65
0
0
0
0
65
0
60
5
0
0
0
0
60
0
80
0
0
0
0
35
0
PART 2
POIHIS
5
25
55
0
0
50
0
20
0
0
75
0
0
40
0
50
0
0
0
0
15
0
PART 3 1
POINTS 1
34
12
40
10
12
27
11
8
14
4
40
5
8
36
IS
25
34
40
24
15
20
16
PART 4
POINIS
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
PART 5
POINTS
0
0
0
20
0
0
0
0
0
0
0
0
50
50
0
0
0
0
0
0
0
0
PART 6
POINTS
0
0
0
0
0
0
0
0
0
0
0
0
10
0
0
0
0
0
0
0
0
0
PART 7
POINIS
0
10
0
0
0
0
0
0
0
0
0
0
0
10
0
0
0
0
0
0
0
0
PART 1
POINT!
0
0
0
0
0
0
0
0
0
0
0
5
0
0
10
0
s
0
to
0
t
5
I RECOMMENDATION IT
I AREA ENGINEER
HO ACTION
ON* REQUIRED
HO ACTION
REC. STUDY Of OPERATIONS
HO Ml ION
.HO ACTION
HO ACTION
IH PIANS t SPECS
HO ACTION
CLEM SEWERS
HO ACTION
HO ACTION
REVIEW OPERATIONS
HO ACTION
HO ACTION
UDM OR) WWTP IMPROVEMENTS
OPERATOR CERT.
IR fAC. PLANNING
rP APPROVED. CET CERT OP
HO ACTION -"
NO ACTION
HO ACTION
HO ACTION
HO ACTION
UNDER CONSTRUCTION
HO ACTION
-------
1987 COMPLIANCE MAINIENANCE ANNUM RE PCM I
60*11
60461
28444
28452
29688
61093
60097
601J5
22)57
22438
22497
60950
29831
MCIUIT NAME
WIS SIATE OVA-VETERANS NOME
Ult STATE UNTVERSI If -PIGEON IAKE SfAIION
UITTENIERG SEUER DEPARTMENT
UOir IREAfMENI PIANT
WMCUOC, VIUAGE
WOODIAKE TRAUS DEVELOPMENT CO. ItO
UHDVIUE viiiAcc or
UOtlpUIPE CHURCH OF GOO
MIGNISTOUN, tOUN OF S. 0. *2
UNIGRTSTOUN SAN DISI HO 1
URIGNISTOUN SEVER t WAIER UIIUIT
VTOCfNA VtllAGC OF
YORK VI I IE SEUER UTIlItT DISfRICT NO. 1
DIST.
IN
Ml
IN
IN
NC
SO
we
NC
IN
IN
IN
SO
SE
DESIGN
.FlOU
0.2900
0.0112
0.2500
3.0000
0.1400
0.0100
0.1080
0.0800
0.0100
0.0400
0.3000
0.1220
0.1500
IOIAI
POINTS
127
11
1)
81
42
40
10
27
36
110
39
83
18
PAR I 1
POINIS
75
0
0
20
15
0
0
0
70
0
0
0
PARI 2
POINIS
0
0
0
0
0
0
0
10
0
0
30
0
PARI 3
POINIS
36
8
26
12
10
6
17
17
40
14
17
8
PARI 4
POINIS
0
0
0
0
0
0
0
0
0
5
0
0
PARf 5
POINIS
0
0
50
10
0
0
0
0
0
20
0
0
PARI A
POINTS
0
0
0
0
0
0
0
0
0
0
0
0
PART 7
POINIS
0
0
0
0
0
0
0
0
0
0
0
10
PAIT 1
POINT
0
0
9
0
0
0
0
0
0
0
S
0
I RECOMMENDATION IT
MEN ENGINEER
HAS RETAINED CONSULTANT
NO ACTION
SlUDCE STORAGE
.REMOVE I/I
NO ACTION
NO MI ION
NO ACTION
NO ACTION
ON* REQUIRED
NO ACTION
NO ACTION
NO ACTION
-------
1987 COMPI lAMCr MAINIfNAMCI ANNIMI IfPClftl
MCII I IT NAME
OfSICN IOIAI PAII I PAII 2 Mil ) PAII 4 PAII 5 PAII 6 PAHI 7 PAtl 8 RCCONNENOAIION if
otsi.riou POIMIS POINIS POINIS MINIS POINIS points POINIS POINIS POINIS MCA CNCINCCR
22195 SI NA1IANI Will SCI*I UII1MT
21857 SfMIEf SCIMCC IIEAIMENI PIANl
60984 SIM PRAIRIC VIIIACC Of
S25SI SICPHCRSVItlC SMUM1 OISIRICI M. t
M216 sicisoRvuu SEIIACC I«AIMENI PIANI
29572 SIEVENS POIRI. CUT or
36285 SIII2ER SMItMl OISIRICI
303*1 SIOCK me CORP no oimii am
21191 SIOCMRIOGC SMIIMf OISIRIC1
28304 tlOOOMD. VIllAGC Of
60925 HONE IMC SMIfMt DISIRICI
20338 SIOUCHIOH SCWACC OISPOSAI PIANl
25569 siRAifORO VIUACC or
20991 S1MN CVIUAGC Of) SCIICI UIHIIT
2II1S SlUMCfOB Mr UlllMICS
60997 ft. KM fRIORf/CI*
J.976 SIMMICO SAN. OISI 01
IIM< SMI I VAN SMI I AIT PISIRICt fl
215M SMI IVAN SCIMCC IKAINCNf HANI
70*; SUM MA1IIC SCWACC 1KAIMEH1 ftAMt
»)9I SUPCtlOl SCIMGC OISPOSAI STSICN
3o*si surcRiai VIIIACC of
200?? SMIK KIMCE 1KA1NCMI PI AMI
205S9 SUSSCI IMSICWAIC* IKAtMCHI MCUIIT
?IS81 1AT1OR SCIMCC IKAINCNt flAHl
?2I22 INMCSA SCIICI I UMCR U1H11»
?03?» miCHSVIllE IMS1CIMIC* 1KA1MH1 PtANt
'56U IMMT> IMSICIMICt IHEAINCNI PI All I
11261 1MVSADO IMIIt.lW
7831 IMKC IAICS SMIIMT OISIIICI 01
'73*9 IICCHIOR.VIIIACC OF
'I3tt ICNAN SCWACC IMAIMNI PIANl
'19*6 IONANAUK CUT Of
MOO IfMT SCIMCC tHAimNI PIANl
09M IKHPfAlCAU SIUAGT IIIAIMENI PIANl
IN
WC
WC
IN
Ml
RC
SO
IN
IN
UC
Ml
SO
NC
WC
IN
WC
IN
SO
SO
SO
mi
MI
IN
sc
UC
so
sc
WC
NC
NC
IN
WC
NC
NW
UC
0.1300
0.597*
0.0591
0.0240
0.1900
4.1000
0.0)00
run
0.0300
1.6500
0.2000
0.1000
0200
0066
2900
1000
0600
1000
0540
1000
,0610
3600
.3460
.0479
.1310
.1000
1.0100
O.«200
0.0226
0.1350
55
117
l?0
117
M
47
HA
70
55
75
15
57
1*5
88
44
22
12
14
9
10
40
15
130
78
92
46
210
243
17
30
1*0
28
80
64
0
45
SO
65
0
0
0
20
0
0
0
s
0
0
0
0
0
0
0
0
30
5
0
0
65
0
80
80
0
0
0
0
0
35
0
10
0
90
60
0
0
5
25
0
0
too
50
0
0
4
0
0
70
15
0
too
0
0
0
to
2
10
2
2
32
40
40
7
11
22
40
0
14
9
12
14
8
10
18
6
40
18
4
6
40
23
2
20
30
18
30
13
0
5
0
0
0
5
0
0
25
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
30
0
0
0
0
0
0
0
0
50
0
20
0
0
10
0
0
0
30
0
30
30
0
0
0
0
0
10
0
0
0
0
0
50
50
0
30
30
0
0
0
to
10
50
0
0
30
0
0
0
0
0
0
0
0
0
8
0
0
0
0
0
0
8
8
8
8
8
8
18
8
18
8
18
8
8
0
0
0
0
1
1
NO AC!ION
IRO ovmoAD. noc POTRS
tCC.SIIVT IOAOIR6S
MO SIUD6C ttORACC
ORR RCCONNCRDCO
NO ACtlON
M ACHON
80 MUM
RltC CORSMIMf. 0 NCICR. CICAN C.S.
HO ACIIOR
NO ACIION
NO ACtlON. NCW HANI
CONtlNUC PlMt UPGRADE
NO ACIIOR
NO ACIIOR
NO ACIION
NO ACIION
NO ACIIOR
NO ACIIOR
NO ACIIOR
NO ACIIOR
StUDCC SIORACC. OPCtAtlONS NOD.
NO ACIIOR
NO MUM
M Ml ION NCW PIANl
NO MIIOR
NO ACIION
URMR CORSIRUCtlON
NO ACIION
NO ACtlON
NO ACtlON
REPIACC MOV MEIER
-------
COMPLIANCE NAINIENANCE ANNUAl RE TOM I
rACUIIT NAME
Of SICN IOIAI PARt t PARt 2 PARI 3 PAH 4 PARI S PARI ft MM 7 Mi? RECOMNENOAIION IT
oisr.riou points points points points points points Points points points MM ENGINEER
25631
60585
21*95
26590
29640
28291
40526
21831
22454
30109
21148
21920
22012
22471
31461
60259
22675
30881
28541
29971
30490
22772
257)9
60011
60178
22276
28843
30678
25763
20389
2t792
28754
22250
2092)
70761
IURHE IA*E. VIllACE OF
twin cit? EASI / IA son
lUin IAKES StVACC IREAtHENt PIANT
tWO RIVERS IIAStEVAIER IHEAIHENt PI Ant
UNIOn CEntER. VIllACE Of
union GROVE SEWAGE IREAIMENI piAnt
unitr. VIIIACE or
VAIOERS VIllACE Or
VERONA CltT OF
VESPER, VIllACE Ot
VIOLA SEWAGE IREAtNENt PI Ant
VIROOUA SEWAGE tREAINENt PI ART
VAKHO S AH It ART DIStRICt *1
UAIPO VAStEWNtER UtllltT
WAiuoRtn countv NEIRO
WARREHS. Vlll Of
UASmum VAStEWAtE* IREAtNENt PlAnt
WAtERlOO SEWAGE DISPOSAL PIANI
WAtERtoun. citT or
WAUKESnA. CltT OF
WAUPACA, CltT Of
WAUPUN SEWAGE IREAIHENt PI AMI
KAUSAU SEWERAGE UtllltT
WAUSAUKEE WAIER ( SEWER III III IT
WAUtOMA, CUT Of
UAUIEM SEWAGE tREAINEnt PIANI
WEOStER, VIllACE Of. SEWER UtllltT
WESt All IS
WESt IEHD, CltT or
WES! SAIEH. VIllACE Of
WESttT SEWAGE tREAtNENt PIANt
WEStERH R ACUTE CO SEW DISI
WEStriElD OISPOSAI PIANt
WETAUVEGA WASIEWAtER IRE AfHENt PIANt
WETERHAEUSER SEWAGE IREAIMEN! PIANt
nw
we
SE
IN
NC
SE
nc
IN
so
nc
we
we
nc
SE
SE
we
NW
so
so
SE
IN
SO
NC
IN
IN
SE
NW
SE
SE
we
we
SE
SO
IN
NW
0.7230
0.0150
0.7100
4.4000
0.0400
1.0000
0.0781
0.1500
0.6250
0.0790
0.1000
0.6000
0.1000
0.1000
3.6000
0.0450
0.2500
0.5390
5.2000
16.0000
1.2500
1.8000
9.2000
0.0800
0.4500
0.0800
0.0800
9.0000
0.5200
0.2298
0.9246
0.4500
0.5080
0.0500
26
58
50
32
135
53
77
57
153
245
76
26
45
70
40
29
130
57
44
87
64
83
121
85
182
101
183
20
14
55
90
61
23
145
29
15
0
0
0
0
0
15
60
50
0
0
0
0
0
60
45
0
65
0
75
25
70
0
20
0
0
15
15
5
0
5
0
0
0
45
0
25
0
40
too
50
0
0
20
0
5
0
0
0
0
0
0
15
0
0
0
15
45
0
0
20
0
36
30
22
40
18
23
32
18
24
8
16
24
40
13
16
2
14
12
34
8
28
30
34
14
20
to
36
8
30
17
0
0
0
0
25
0
0
0
0
a
0
0
0
0
0
0
0
0
0
0
0
15
0
0
0
0
0
0
35
0
0
20
10
20
0
0
0
0
0
0
to
0
10
0
0
0
30
0
20
0
0
20
20
0
10
10
0
10
50
0
0
0
0
30
0
0
0
10
0
0
0
0
0
0
0
0
0
0
10
0
0
0
30
0
0
10
0
0
10
0
0
0
0
0
10
0
10
20
10
0
0
0
0
0
0
10
0
10
0
0
0
10
0
0
It
0
10
0
0
0
0
0
0
0 '
10
0
S
0
0
0
10
0
S
0
0
0
0
0
0
0
0
5
0
0
0
0
0
0
no Action
no Action
RPt.StAIUS SlUDGE 8EOS
HO ACtlON
OUR REQUIRED
HO ACtlON
ONR IE COMMENDED
HO Action
ONR. rp, oisinrEc. SIUOT
EVAl. TREAT. STSTEN, MC. PIAN
HO ACtlON
HO MIIOH
no Action
HO MIIOH
M ACtlON
MCllltlES PIAN
HO ACtlON
HO ACtlON
HO MIIOH
HO Ml ION
HO Ml lOH
OimntlT UPGRADING
ONI RECOMMENDED
ONI. rACHIIIES PIAN
OPER. ED.. OSN NANUAt, SlUDGE SIOMI
MC. PIM
NO ACtlON
CHIT RENOVAl
UPGRADE AERA1ION, REDUCE CIEAR WAtEl
no Action
NO ACtlON
ONR REQUIRED
NO ACtlON
-------
1987 CCMPUAMCE MAIH1EHANCE AMMUAl SEPOST
?8509
315*9
70044
79017
35581
21865
2010?
61069
35904
71796
11348
30641
70117
71032
79394
37221
60496
7883$
79041
76352
77802
78967
78478
40810
78975
>093I
'9076
'1288
9319
8355
1496
1018
1721
0929
1555
Mcnnr NAME
AEcsEviuE. vi 1 1 Act or
REVET, VIUAGE or
RHINEIANDER SEWAGE TREAIMENI PlANf
RIB IMC. VIllAGE OF
RIB MOUNTAIN MEIROPOUTAN SEWERAGE OISIRICT
RICE LAKE WASTEWATER TREATMENT PlANf
RICHLANO CCNIER SEWAGE TREATMENT PI AMI
RICHMOND TN SO »1
RIDGE VIEW INN. INC.
RIDGEIANO SEWAGE tREAIHENf PlANf
RIDGEUAV. VIllAGE OF
RIDGEWAT COUNIRT ClUB. INC.
RIO SEWAGE TREATMENT PIANT
RIPON WASTEWATER FACIIITT
RIVER FAllS. CITY OF. MUNICIPAL UllllfT
RIVER NIllS VIllAGE OF
RIVEREDCC COUNTRY ClOB
ROBERTS, VIllAGE OF
ROCK SPRINGS SEWER AND WATER UTILITT
ROCKDAIE. VIllAGE OF
ROCKIANO SAHITARV DISTRICT «1
ROCKIAND WATER AND SEWER UllllTIES
ROSENDAIE SEWAGE TREATMENT PIANIS
ROSmUT SEWER COMMISSIOH
ROKBURT SANITARY OISIRICT f 1
ROTAl SCOTT SANITARY DISTRICT ft
ROmiVILLE SANITARY DISIRICT NO 1
RUDOLPH SEWACE IREAIMENT PIANT
RUSSEU TN SANITARY DISTRICT »1
SAIEN OTIIITY DISTRICT NO.T
SAIEM UTIIITY DISTRICT NO. 2
SAND CREEK S.D.IT
SAUCER §. POWERS. COBRECMOMAl CENTER
SAIK CO HEAITN CARE CENTER
SAUKVIllE SEWER UflllTV
DIST.
SO
SO
NC
NW
NC
NW
SO
we
we
we
SO
IM
SO
SO
we
SE
NC
we
SO
SO
IM
we
SO
NC
SO
IN
NC
NC
NC
SE
SE
we
IM
SO
SE
DESIGN
FLOW
0.1000
0.0250
1.9000
0.0960
4.9400
2.8800
1.6000
0.0075
0.0130
0.0320
0.0680
0.0060
0.1150
2.0000
1.8000
0.0075
0.1950
0.0768
0.0250
0.0190
0.0400
0.1380
0.1000
0.0200
0.0520
0.0300
0.1200
0.0300
0.3000
1.5700
0.0323
0.0090
0.0420
1.0000
TOTAl
POINTS
201
a
70
12
37
53
81
4?
91
17
160
93
11
52
44
0
51
106
32
42
110
131
40
59
130
58
45
192
78
59
39
24
104
146
59
PART 1
POINIS
40
0
0
0
0
0
0
25
0
35
0
0
0
0
0
0
0
0
0
30
60
0
0
50
0
0
60
15
0
0
0
60
25
0
PAR1 2
POINIS
100
0
0
0
25
15
0
60
0
70
55
0
0
0
0
0
100
0
10
20
35
0
0
0
30
15
75
10
15
25
5
0
80
0
PART 3
POINIS
6
8
20
12
2
26
16
6
a
15
38
8
22
14
40
«
24
32
23
36
10
37
26
20
3
9
19
34
14
10
5
5
14
PART 4
POINIS
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
5
PART 5
POINIS
0
0
50
0
0
30
0
0
0
0
0
0
30
30
0
0
0
0
0
0
20
0
0
0
0
0
0
0
0
0
0
0
30
PART 6
POINIS
0
0
0
0
0
to
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
PART 7 PART
POINTS POIN
0 5
0 0
0 0
0 0
10 0
0 0
0 10
0 0
0 5
0 fl
0 «
0 0
0 1
0 (
0 5
0 (
0 (
0 (
0 If
0
10
1
10
0
0
0
0 I
10 (
8 RECOMMENDATION BY
TS AREA ENGINEER
CORRECT I/I. SEND INSPECTION SCHEDULE
NO ACTION
SlUOCE STORAGE
NO ACTION
NO ACTION
NO ACTION
OSNR INITIATED
|
SUPPORT PROP. ACTIONS
FOIIOW OWNER'S RESOLUTION
NO ACTION
1 NO ACTION
1 ONR RECOMMENDED
1 NO ACTION
1 NO ACTION
1 NO ACTION
NO ACTION
» NO ACTION
1 NO ACTION
1 NO ACTION
t NO ACTION
1 CLEAN POND BOTTOMS
NO ACTION
NO ACTION
CARRYOUT I/I RESOLUTION. OPERATOR ED.
NO ACTION -
ONR
NO ACTION
NO ACTION
NO ACTION
NO ACTION
IMPROVE 0 ft M
) NO ACTION
»
-------
1987 COMPLIANCE MAIN1ENANCE ANMIAl REPOAI
6053*
jiw
60186
35866
?6654
60038
21769
22608
2028?
25411
25453
20095
31127
28100
30945
28321
20851
28924
22071
20290
22241
61115
30252
28819
22292
20737
21521
21067
60801
22373
30520
26867
20796
35980
31186
MCIIIIY NAME
S AUK PRAIRIE Sri/ttAGE COMMISSION
SAVON UNIt ART DISTRICT
SCANDINAVIA SEWAGE TREATMENI PI AN!
SCNOOl DISIIIC1 or SUPERIOR
SEVASTOPOL SANITARY OIS1 NO 1
SENTOMVIllE SANITARY DISfRICt
SETNOIR WASTEUATER TREATMENT PLANT
SHARON VILLAGE Of
SHE80TGAN CO COMP HEAL IN CTR
SREMV6AN SEVAf* 1REA1MENT PLANT
SHELDON SEWAGE TREATMENT PLANT
SHELL LAKE SEUAGE IREATMENI PLANT
SHERWOOD. VILLAGE Of
SNIOCTON UTILITIES
SNOREUOOO VILLAGE Of
SMJllSBURG. CITT or
SILVER LAKE VASTEUATFR TREATMENT PLANT
SIREN, VIII ACE Or
SISTER MY WASTEUAIER TRFAIMENf PIANI
SLINCER SEWAGE TREATMENT PLANT
SOIOIERS GROVE SEWAGE TREATMENT PLANT
SOLON SPRINGS. VILLAGE OT
SOMERSET. VILLAGE OT
SOUTN MILWAUKEE WASTEWATER TREATMENT PLANT
SOUTH WAYNE UASTEWATER TREATMENT PLANT
SPARTA WASTEUATER TREATMENT PLANT
SPENCER SEWER UTILITY
SPOONER SEWAGE TREATMENT PLANT
SPRING GtEEN. SEUAGE DISPOSAL PLANT
SPRING VALLET SEWAGE TREATMENT PLANT
Sf CLARA CONVENT
ST CLOUD UIILIIT COMMISSION
ST CROIK TAILS SIP
SI CROIK MEADOWS MHP/LANOMIL INC.
Sf JOSEPH SANIIART DISTRICT
DIST
SO
NW
LM
NW
IN
SO
LM
SE
SE
SE
NU
NW
IN
LM
SE
SO
SE
NW
LM
SE
we
NW
we
SE
SO
we
NC
NW
SO
we
so
so
NW
NW
we
DESIGN
.now
1.0000
0.0140
0.0500
0.0100
0.0780
0.0500
0.5780
0.3250
0.0673
18.3900
0.8640
0.1950
0.0500
0.1500
0.2880
0.3000
0.1880
0.3000
0.7600
0.1 140
0.1500
6.0000
0.0530
1.5000
0.2860
0.5670
0.2600
0.1890
0.1000
0.0440
0.1800
0.0500
TOTAL
POINTS
12
28
38
47
25
120
10
36
62
50
9
14
37
34
0
13
103
13
148
57
106
32
62
56
66
75
283
70
22
21
40
8*
51
131
54
PART 1
POINTS
0
0
5
25
0
65
0
30
0
0
0
0
0
0
0
5
40
0
40
0
0
0
0
10
60
0
15
0
0
30
30
PART 2
POINTS
0
0
0
TO
0
0
0
0
0
0
0
5
0
0
5
45
40
5
30
0
0
0
0
20
100
0
0
0
40
50
0
PAR! 3
POINTS
8
11
14
0
14
10
10
6
32
10
8
13
14
0
8
to
21
12
36
10
12
6
36
40
28
12
6
40
23
2
24
PART 4
POINTS
0
0
5
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
5
0
0
0
0
0
0
PART 5
POINTS
0
0
0
0
0
0
0
0
30
30
0
0
0
0
0
0
0
TO
0
0
50
30
0
0
50
10
0
0
0
0
0
PART 6
POINTS
0
0
0
0
0
0
0
0
0
0
0
20
0
0
0
0
TO
0
0
0
10
30
0
30
0
0
0
0
0
0
PART 7 PART 8 RECOMMENDATION IT
POINTS POINTS AREA ENGINEER
0 0 NO ACTION
0 10 NO ACTION
0 0 NO ACTION
0 0 NO ACTION
0 5 . NO ACTION
0 0 ASSESS LEAKAGE
0 0 NO ACTION
0 0 NO ACTION
0 0
10 0
0 0 NO ACTION
NO AC! ION
10 0 NO ACTION
0 0 NO ACTION
0 0 NO ACTION
0 0 NO ACTION
0 0 REDUCE I/I
NO ACTION
10
20
0
10
0
10
0
0
10
0
0
0
0
FACILITY PLAN APPROVED
CHECK INO LOAD. CLEAN COIL STS
NO ACTION
CONSIDER AW. SLUDGE STORAGE
-
NO ACTION
ONR
IN FAC. PLANNING
NO ACTION
NO ACTION
NO ACTION
NO ACTION
IN EAC. PLANNING
0 0
0 0 NO ACTION
-------
1987 COHPI MICE MAINIENANCE ANNUM REPORT
31259
2*988
71181
77870
77861
78461
75011
78550
70753
77733
30503
70681
71709
75070
75038
750(6
709(0
3*077
60933
25062
11020
30(81
71644
29033
77705
299(7
77811
10651
29050
,M539
'5119
'9637
11089
8711
0494
r ACUITY NAME
OAKDALE SANITARY DISTRICT
OAKFIELD SEWAGE SYSTEM
OCONONOUDC WASTEWA1ER TREATMENT PLANT
OCONIO FAL1S SEWAGE DISPOSAL PLANT
OCONTO UTILITY COMMISSION
OGENA SANIIARY DISTRICT
ONRO MUNICIPAL SEWAGE TREATMENT PLANT
ONOOSSAGON PUBLIC SCHOOL
ONTARIO SEWAGE TREATMENT PLANT
OOSTBURG WASTEWATER TREATMENT PLANT
ORCHARD MANOR
OREGON MUNICIPAL WATER AND SEWER UTILITY
ORFOROVIllE SEWAGE TREATMENT PLANT
OSCEOLA SEWAGE TREATMENT PLANT
OSNKOSN WASTE WATER TREATMENT PLANT
OSSEO SEWAGE TREATMENT PLANT
OWEN WATER SEWER UTILITY
OXFORD. VILLAGE OF
PACKWAUKEE SAN. OIST. 01
PADDOCK LAKE SEWAGE TREATMENT PLANT
PALMYRA SEWER AND WATER UTILITY
PARAMSKI MOBIL HONES (TOWN OF BRISTOL)
PARDEEVIllE WATER t SEWER COMMISSION
PARK FALLS SEWAGE TREATMENT PLANT
PATCH GROVE SEWAGE TREATMENT PLANT
PENCE. TOWN OF
PEPIN SEWAGE WASTE TREATMENT PLANT
PESRTIGO WATER I SEWER UTILITY
PRE1P$ SANITARY DISTRICT 0 1
PHILLIPS SIP
PIGEON FALLS SEWAGE TREATMENT PLANT
PIKES BAT SANITARY DISTRICT
PINE VALLEY MANOR
PINEVIEW MOBILE NOME PARK
PIITSVILLE WATER AND SEWER DEPT.
DIST
we
so
SE
IM
IN
NW
IM
NW
we
SE
so
so
so
NW
IN
we
we
so
so
SE
SE
SE
SO
NW
SO
NW
we
IN
NC
NW
we
NW
so
we
NC
DESIGN
.FLOW
0.0750
0.3050
4.0000
0.5000
1.7600
0.0500
0.5400
0.0120
0.0860
0.2810
0.0400
0.9300
0.4000
0.5240
20.0000
. 0.2310
0.4260
0.0600
0.0500
0.5600
0.2300
0.0400
0.3142
1 .0550
0.0250
0.0520
0.1500
4.6500
0.1000
0.3000
0.0500
0.0360
0.0562
0.2000
0.0900
TOTAL
POINTS
41
23
80
40
110
132
23
65
14
52
28
78
22
77
29
7
155
29
155
220
25
48
37
65
151
120
155
79
110
25
6
83
90
59
31
PART 1
POINTS
10
15
0
0
0
20
5
0
0
5
20
70
0
0
35
0
80
65
0
15
5
SO
80
60
35
15
0
0
0
0
20
PART 2
POINTS
0
0
' 0
20
0
55
0
0
0
0
0
0
5
0
80
15
0
90
0
5
25
100
0
35
15
45
25
0
45
15
0
PART 3
POINTS
11
a
70
10
30
14
18
34
14
12
8
8
24
6
2
7
12
40
9
3
4
1
40
30
14
23
0
4
40
34
6
PART 4
POINTS
0
0
0
0
0
0
0
0
0
5
0
0
0
0
0
0
0
25
0
0
5
0
0
0
0
0
0
0
5
0
0
PART 5
POINTS
0
0
30
10
50
0
0
0
0
30
0
0
0
0
0
0
0
0
0
0
0
0
0
30
10
0
0
0
0
10
0
PART 6
POINTS
0
0
20
0
30
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
PART 7
POINTS
10
0
10
0
0
0
0
10
0
0
0
0
0
0
0
0
0
0
10
0
10
0
0
0
0
0
0
0
0
0
0
PART 1
POINT!
0
0
0
0
0
10
0
5
0
0
0
0
0
0
0
0
s
0
0
0
0
0
0
0
s
0
0
0
0
0
s
RECOMMENDATION BY
AREA ENGINEER
NO ACTION
NO ACTION
NO ACTION .
SLUDGE STORAGE
ONR
NO ACTION
NO ACTION
IMPROVED MAINTENANCE RECOMMENDED
NO ACTION
JUSTIFY CAP. IN ONR
NO ACTION
REPRESENTATIVE SAMPLE
NO ACTION
NO ACTION
NO ACTION
NO ACTION
LEAKY LAGOON. 7 NIGH FLOW READINGS
UNDER CONSTRUCTION
NO ACTION
NO ACTION
NO ACTION
NO ACTION -"
NO ACTION
ONR required. cone ld»r wty.tludge store
ONR
NO ACTION
NO ACTION
NO '86 OR '97 REPORT YET
RCC.OtN REVIEW
NO ACTION
-------
1907 COMPLIANCE MAINIEMANCC ANMMI RErORI
360(8
60062
20(35
6061 1
30589
28380
307(1
27995
21(31
3105*
30031
20(51
20(60
29670
35998
20*27
215*7
29025
316V1
21091
20257
2)178
21075
22(03
22055
2083(
2519(
60798
60607
31160
21(15
21661
20729
20371
7IJ42
EACH nr NAME
PIAIN, VIUAGE or
PtAINHEtO, VILLAGE OF
PIATTEVIllE SEWER Of PI.
PLEASANT ACRES NURSING NONE
PLEASANT PARr UT III IT CO. IRC
PIEASANT PRAIRIE UIIL 0151 0
PLEASANT PRAIRIE UtllltT DIStRICf R73-1
PIOVER (VIllACE OF)
PLUM CITY SEWAGE IREAIMENt PlANt
PLYMOUTH TOWN SAN if ART DISTRICT i
PLYMOUTH UtlUUES COMMISSION (HUNICIPAt)
PORf EDWARDS WASTE WATER TREATMENT PIANT
PORT WASHINGTON WASTEWAIER TREATMENT PLANT
PORT WING TOWN OF
PORTAGE PFTRO IRUCt STOP
PORTAGE SEWAGE TREATMENT PIANT
POIOSI WAS1EWAIFR TREATMF.NI PIANT
POTTER SARI TART DISTRICT
POT SIPPI SANMART DISTRICT
POTNETTE SEWER UMIITT
PRAIRIE DO CHIEN WASTE TREATMENT MCUITIES
PRAIRIE FARM SEWAGE TREATMENT PLANT
PRENTICE. VIllAGf OF
PRESC01T SEWER 01 III IT
PRINCE ION SEWAGE TREATMENT PLANT
PUIASKI WASTEWATER TREATMENT PIANT
RACINE WATER AND WASTEWATER UTILITY
RADISSON SEWAGE TREATMENT PIANT
RAl -YIELD EOUITIES II
RANDOLPH, VIIUGE OF
RANDOM IAKE SEWAGE TRFAIMtNl PIANT
READSIOVN SFWAGE IREAIMENt PI ANT
RtDGRANITE SEWACT 1REAIMENI PLANI
REEOSBURG SEWAGE IRFAIMENI PIANT
RFEDSVUIE UASItUATER TREAIMENf f Add IT
DIST
SO
IN
SO
NC
SE
SE
SE
NC
we
SO
SE
NC
SE
NW
SO
SO
SO
IN
LM
SO
we
NW
NW
we
SO
LM
SE
NW
SO
SO
SE
we
LM
SO
IN
DESIGN
.FIOW
0. 1050
0.0970
1.6000
0.0200
0.0600
0.5554
0.4000
0.5500
0.0600
0.0300
1.6500
0.5600
1.0000
0.02(6
0.0*10
2.0000
0.3300
0.0(00
0.0(80
0.1900
2.0000
0.0500
0.1000
0.3500
0.2770
0.0000
30.0000
0.0300
0.9100
0.4500
0.0700
0.1000
i.tooo
0.1600
TOIAL
POINTS
U
67
53
33
U5
29
38
93
52
(5
103
3*
215
1*1
189
133
30
(6
118
(0
139
70
60
82
50
6*
25
60
88
20
(1
28
222
16
iC
PART 1
POINTS
0
25
30
0
80
5
0
(5
0
60
80
70
60
60
0
0
0
10
25
30
15
30
10
5
10
5
0
0
60
0
30
PART 2
POINTS
0
0
0
5
0
0
0
25
25
0
30
5
65
«5
0
10
65
0
90
0
5
0
25
0
0
0
0
0
90
0
0
PART 3
POINTS
U
17
8
20
(0
(
28
0
12
18
30
21
2
8
30
36
U
10
2(
20
32
8
3
20
(0
10
16
28
22
6
28
PAIT (
POINTS
0
0
5
0
25
0
0
0
0
0
5
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
PART 5
POINTS
0
0
0
0
0
0
0
0
10
0
50
0
0
0
0
0
0
0
0
0
30
0
0
0
0
0
?0
0
50
10
0
PART 6
POINTS
0
0
0
0
0
0
0
0
0
0
10
0
0
0
0
0
0
10
0
0
0
0
0
0
0
0
0
0
0
0
0
PART T
POINTS
0
0
10
0
0
20
10
0
0
20
10
0
10
20
0
0
0
10
0
10
0
0
10
0
0
0
0
0
0
0
0
PART
POINT
0
0
0
s
5
0
10
5
0
0
0
10
0
0
10
s
s
0
0
0
0
B RECOMMENDATION IV
1 AREA ENGINEER
HO ACTION
NO ACTION
NO ACTION
NO ACTION
,rACUItY BE INC ABANDONED
M Ml ION
NO ACIION
NO Ml ION
NO MtlON
NO ACTION
NO ACTION
CORRECT FLOW MEASURE
REPRESENTATIVE SAMPLE. SS VAN. NEEDED
ONR REWIRED
NO ACTION
NOMflON
NO ACTION
UPDATE FP
SUBMITTING ONR
NO Ml ION
IMPROVE ifRUC.INTEG.
NO MtlON
EXPLAIN BACKUPS
NO MtlON
OPERATOR CERT.
NO ACTION
NO ACIION
ONR REQUIRED
NO ACTION
NO ACTION
-------
1987 COMPIMNCE NAIN1ENANCE ANNUAl REPORt
76182
torn
24619
HUT
2102*
60160
246IS
2(641
24651
16711
20111
74671
25181
24701
10951
root
20150
24712
61042
29742
11500
72)01
24741
60451
76075
74767
74775
?9I06
J479I
U919
'1)69
0591
0)62
(01)
(021
MCI1IIT MANE
MARINE HE CUT Of WAS1EUAIER IREAINCNf PI AMI
MARION SEWAGE IRCAINENI PIANI
NARKCtAN JOINI WAIER AND SEWER UIIIIIV
NARSNAll SEIMGC IREA1MENI PIANI
NARSHMCIO WASIEUAIER IREAIHCNI PIANI
NAIIOON Vlll Of
NAUSION SEWAGE 1REAINENI PIANI
NATviut sttcR mum
NA20NANIE SEWAGE IREAINENI PIANI
Koran, citr or
NEIICN KWCC IKAINCNI PIANI
NEllOSf SCVAGE IRCAINCNI HANI
NENONONIC MttS. VIUACC Of
NENONONIf IMSICWAICR IREAIHCNI PtANI
MOWN, CMV Of
NCRCER, tOM Of . S. 0. « 1
NEMIU SCIMGf lHAINENr HM1
KHI11M. VIIIACC Of
NEHIfUC, VIIIACC Of
NIOOlE RIVCI MEAltM fACHIIT
NI1AV $.0.
NIUADORt KUACf 1HAIMENI ft AMI
Will lOUN SCIMCt IMAIMNt flAHf
Nil 1 ON IMSIIIM1EI IMEAtNEHr flAMI
NlitMUKCC cur or
MIIIMUKIf NiltOfOlllAN SEUEIACf OlStRICI Jl
NitiiMKEK NfinroiHA* ftutiAct oisimcr ss
NIMWRO SMIIARY OlStllCt «1
NIMMl fOW IMIICIMl SEWAGE PIAHI
NIVON8. VIllMi M
NIMICOT MtiR AM) SEUCO UlllllT
HONDOVI UAflEWAUl TREA1NEMI PI AMI
NOHtoE, cm or
MONffllO MASIfUAIER IRfAINfHI PI AMI
NONirmi stuc* ofpf
OlSt
IN
IN
so
so
HC
IN
MC
SO
SO
NU
Ml
we
SE
we
SI
Ml
HC
we
SO
Ml
NC
NC
Ml
SO
sc
SE
SC
we
so
Ml
IN
we
SO
SO
SO
DESIGN
.now
4.2500
0.2400
O.)860
0.1100
1.5000
0.0)70
1.0000
1.1000
0.1600
0.0400
0.1400
0.0500
2.8800
0.1000
2.1400
0.0650
0.0520
0.0450
0.0600
0.04)0
0.0900
0.5000
200.0000
120.0000
0.0100
0.2780
0.1000
0.1880
0.2870
1.5700
O.)000
0.0)60
IOIAI
points
167
34
8
28
77
1)9
154
1)
80
111
146
94
0
4
0
SO
56
7
80
72
152
60
22
14
50
65
5)
1)4
18
22
1)4
102
67
17
59
CADI 1
POIMIS
80
20
0
IS
10
60
0
0
20
60
0
0
0
0
0
0
40
0
s
0
50
0
5
60
0
80
40
0
)5
PMI 2
MINIS
0
0
0
0
55
10
0
0
ss
50
65
0
4
0
0
10
0
0
too
IS
0
0
0
0
IS
0
15
50
0
0
PAtl )
POINIS
)2
14
10
6
0
A
0
40
26
0
12
14
20
12
40
28
26
18
6
2
12
4
PAII 4
POIMIS
5
0
0
5
0
20
S
0
0
0
0
0
0
0
$
0
0
0
0
25
20
0
0
0
0
0
5
PAII 5
POIMIS
50
0
0
0
to
0
10
SO
10
0
0
0
to
0
0
20
0
0
0
0
0
0
0
0
0
0
0
PAHI 6
POIMIS
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
PAtl 7
MINIS
0
0
0
0
0
0
10
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
to
0
0
Mil 1
POIM11
0
0
0
0
0
0
0
0
0
0
0
0
0
0
s
0
0
0
0
0
0
0
5
0
1 mOWENOAHON IT
MCA ENGINEER
CONIINUC UPGRAOC
REDUCE I/I
NO AC t ION
NO ACIION
INPROVC NAINIENANCE
ONR
CONPtCIE ONR
ONR RECONNCNKO
CONSItUCriON UNOCRWAT
NO ACHOR
REVIEW 0. I N.
NO ACIION
NO ACIION
NO ACIION
NO ACIION
NO ACIION
NO ACIION
DC-CI/CKPAMD SIC. OCO
MAM ICHCR Or AGREENEN!
ClIN. CICAR WAIER
NO ACIION
NO ACIION
NO ACIION
NO ACIION
NO ACIION *
NO ACIION
NO ACIION
DCVCIOP MC. PI AN
PXWIIOR 1*0.. f A/1 IN OPS
NO ACIION t'
NO ACIION
-------
WOT COMPLIANCE MAINIENANCE AMMUAl BfPOB!
2(830
22306
60712
22390
35963
20907
20281
606*0
2026S
60615
20133
26085
21202
20611
29(59
60666
30635
29998
20061
20893
20699
24929
29807
212(5
2(911
29(67
20508
31(53
26011
35(75
60879
611(0
2(961
31(70
J?2I2
F ACUITY HAW
MONTICEUO. VILLAGE Of
MONTREAL VASTEVATER TREATMENT PLANT
MORRISONVIllE SANITARY DISTRICT
MOSINEE UAICt AND SEUER UfllllT
NOUN1 CAIVARV
MOUNI NOPE SEWAGE TREATMENT PI AMI
NOIINt HOREB
MOUNT TELEMARK IOOGE
MUKWONAGO SFUAGC TREATMENT PLANT
MUscooA. viiiAct or
NECEDAH. VIllAGE Of. U1IIIIT DEPARTMENT
NEENAN-NENASHA SEWAGE COMMISSION
NEILLSVIllC. CUT OF
NEKOOSA. CIIY OF
NEISON SANITARY DISTRICT t 1
NESHKOPO. VILLAGE OF
NEW AUBURN. Will OF
NEW BERUN PUBIIC SCHOOLS
NEW ClARUS UASIEUATER TREATMENT PIANI
NEW HOtSTEIN WASTEUATER TREATMENT PLANT
NEW IISBON SEWAGE TREATMENT PIANT
NEW LONDON WASIEWATER PLANT
NEW MEDICO REHAB SERVICES OF WISC INC
NEW RICHMOND
NEUBURC SAM II ART DISTRICT {VILLAGE )
NIAGARA WATER POUUIION CONTROL CENTER
NICHOLS WASIEUAIER IREAIMENI PLANT
NORTH BEND S.O. ft
NORIN FREEDOM SEWERAGE UIIMIT
NORTH LAKE POTGAN SANI1ART DISTRICT
NORTHERN MORAINE UTILITY COMMISSION
ROUT HI AMD MISSION INC.
NORWALK SEWAGE TREATMENT PIANT
NORWAY TOUN S.O.fl
OAK CREEK CUT OF
DIST
SO
NW
SO
NC
SO
SO
SO
NW
SE
SO
NC
IN
we
NC
we
SO
we
SE
SO
LM
NC
LM
SE
we
SE
IM
LM
we
SO
IM
SE
IM
we
SE
SE
DESIGN
.FLOW
0.18(0
0.6500
0.2010
0.5500
0.1700
0.0200
0.6000
0.1000
1.5000
0. 1250
0.1300
18.0000
0.5200
0.5000
0.0360
0.0600
0.0630
0.02(0
0.2550
1.3300
0.2000
1.0950
0.0250
0.8(60
0.22(0
0.3900
0.0500
0.0100
0.0700
0.0300
0.6000
0.0(50
0.1(00
0.7500
TOTAL
POINTS
71
31
(0
96
1((
22
85
(3
22
IK
(2
(5
98
13(
117
(8
16
93
85
26
71
195
(3
36
65
51
68
35
19
NA
(8
(7
121
33
0
PART 1
POINTS
5
0
0
0
0
(5
0
35
(0
0
50
0
0
?0
0
0
(0
0
0
25
20
0
0
15
55
10
0
PART 2
POINTS
0
0
80
5
0
10
0
0
0
100
10
5
30
25
0
35
too
0
0
0
5
0
0
0
30
5
0
PART 3
POINTS
16
13
23
20
28
16
22
0
28
34
18
5
(0
(0
26
6
0
38
6
(0
26
28
1(
16
26
18
0
PAR1 4
POINIS
0
0
0
10
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
PART 5
POINIS
50
0
0
SO
0
0
20
10
10
0
0
0
0
0
0
20
50
0
20
0
0
30
0
0
10
0
0
PART 6
POINTS
0
0
0
0
0
0
0
0
20
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
PART 7
POINTS
0
10
0
0
10
0
0
0
0
0
0
0
0
0
0
10
0
0
to
0
0
10
0
to
0
0
0
PART 8
POINTS
0
0
, 5
0
0
0
0
0
0
0
10
0
0
0
0
. 0
0
RECOMMENDATION BY
AREA ENGINEER
IMP. I/I ft SLG.STR.
NO ACTION
IMPROVEMENTS
NO ACTION
NO ACTION
SUPPORT BO.REC.
NO ACTION .
FORMALIZE Pi ANN ING
ONI
ONR RECOMMENDED
FAILED SYSTEM. NIRE CONSULTANT
NO ACTION
ONR RECOMMENDED
H NAll IE ONR
NO ACTION
VISIT. FUTURE REC.
EXAMINE LOADINGS
NO ACTION
NO' ACT ION
NO ACTION
IMPROVE 0 ft M
NO ACTION
NO ACTION. POSSIBLE IKY LAGOONS
NO ACTION
ACTION UNDERWAY
NC -ION
NO ACTION
-------
191); COMPI IANI.I MAINirNANCf ANNIJAI DIPCMI
31933
31038
7 ISM
31755
10627
303)0
24333
72161
30568
78070
71474
torn
35548
M976
40224
JO) 16
'0rOI
mi
0176
OKI
9789
0500
8941
046*
8169
9581
1487
U65
UF8
1911
>3?6
130
194
t?9
113
MCII llr MANE
IROHUOOO. CUT Of
IIONIA SANIIAAT OISIRICI « I
JACKSON SEWAGE IREAINENI PI Ml
JAMES !OUM SANIIARf OISIRICI i S
JAWS lOW MNIIMT OISIRICI »2
JANESVIUE UAIER POUUtlON CONIROl Ulllllr
JEMENSON WASIEUAIER IREAINENT HANI
JOHNSON CIEEK. VlllAGf Of
JUDA SANIIART OISIRICI
JUKI ION cm. vitiAGf or
JUNtAU UASIEUAIEA IREAINENI MAN!
J«l Oil INC C/0 KERBERI JONES
KEKOSCEE-tEROT SANIIARr OISIRICI
KEUNERSVIIIE. VULAGf Of
mir lAKf 8.0. »l
KENDAU SEWAGE IREAINENI PIANI
KENOSRA, ClfV Of. WAIEA Ullllll
KEUASKIM SEUACE IREAINEHI PI AMI
KEWAUNEff WAtlEWAIER IREAIMENI PI AMI
Kill WASIEWAIER IREAINENI PI AMI
KIEIER SANIIART OISIRICI t 1
MAPP. VIUAGE Of
KNIGNI, IOUN OF
MOIN.es NANACCNENI CORP.
KRACOU SMIIMT OISIRICI
IA CROSSC. CUT Of 8ARRON ISIANO
IA CROSSE CUT Of
IA fARGE SttMCC IREAINENI PI AMI
iA VAUC. VlllAGf Of. SEMRAGC UlllllT fUNO
IACROSSE NOfllE NONES INC MOOKVICW NNPNNP
IAOTSNIIN IMSIEWAIER IREAINfNI PIANI
IARE GENEVA IIASIEWAIfR IRfAINENl PtANI
IAKE Nlllt. CIIV Of
IARE MtAGANON SIWACE COHNISSKIN
IAKE UAPOGASSEI-BfAR IRAP IAKE SAN OISI
OISI
NW
SO
SE
SO
so
so
so
so
so
NC
so
so
so
IN
IN
we
SE
SE
IN
IN
SO
we
NW
NW
IN
we
we
we
so
we
NW
SE
so
NW
HU
Of SIGN
.rtou
0.1000
0.8700
0.0088
0.0100
17.1880
1.7000
0.2800
0.0400
0.0560
0.6100
0.0100
0.017S
0.04SO
0.0800
0.0700
78.0000
1.0000
0.5800
0.8620
0.0900
0.0400
0.0120
0.0074
0.1000
0.0400
20.0000
0.1720
0.0)70
0.0200
0.64 SO
2.4150
1.0200
1.0000
0 0500
IOIAI
POINIS
IS
91
32
101
164
2
9
38
110
246
25
32
201
18
61
44
36
112
80
40
6
140
47
49
42
67
85
9
84
47
90
5
IB2
19
22
PAITI 1
POINIS
5
80
0
65
0
0
30
60
40
5
0
SO
0
0
60
40
0
80
20
s
0
0
0
20
0
0
60
0
PARI 2
POINIS
0
5
0
0
0
s
0
0
too
0
0
70
0
0
0
0
0
5
0
0
0
0
0
15
0
50
SO
0
PARI )
POIHIS
0
8
12
II
2
4
8
3
30
10
28
6
It
34
20
8
6
20
1)
28
32
2
4
18
32
40
12
12
PARI 4
POINIS
to
0
0
0
0
0
0
0
15
0
0
25
0
0
0
0
0
0
0
0
0
0
$
0
0
0
0
0
PARI 5
POINIS
0
0
0
0
0
0
0
0
0
0
0
0
0
10
0
0
0
0
0
0
0
50
0
0
to
0
so
0
PARI 6
POINIS
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
PAR! T
POINIS
0
0
20
0
0
0
0
0
0
10
0
0
0
0
0
10
0
10
0
0
10
0
PAR! 1
POINU
0
0
0
0
0
0
0
0
0
0
0
0
0
0
10
It
5
0
0
s
0
0
0
1 RECOMMENOAIION IT
t AREA ENGINEER
NO AC t ION
DECREASE I/I
EVAIUAIE IEAMGE
NO ACIION
NO ACIION
rouow s.o. CM
PtMS AND SPECS ARE IN
NO ACIION
NO ACIION
CHECK INflNI. IO.-NEED AIG. VAR.
NO ACIION
NO ACIION
NO ACIION
OM
NO ACIION
NO ACIION
CAllMAIE.riOUNEIER
NO ACIION
CERIIfT OPERAIOR
NO ACIION
NO ACIION
OM
NO ACIION
NO AC! ION
NO ACIION
UllOING NEW PIANI
NO ACIION
NO ACIION
NO ACIION
-------
1VB7 COMPLIANCE MAIMfrNANCE ANMUAl REPORI
29335
61387
2283 T
30732
24503
29)86
28592
31925
31)64
61361
31828
21980
31968
22187
22918
291 U
20532
60763
29271
22179
31917
21*82
21911
60(88
31941
30759
24597
32361
20869
24601
29718
79009
70273
61051
FACILITY NAME
LAKEIAND COLLEGE
LAKELAND SANITARY DIS1RICT NO. 1
LAKELAND 9.0. ft (WOODRUFF -NINOCOUA)
LAKEVIEW N08IIE HOME PARK
LANCASTER SEWAGE TREAINENI PLANT
1ANO O IAKES SANITARY DISTRICT 01
IAOHA SANITARY OISIRIC1 MO. 1
IARSEN-WINCHESIER SAM. OlSf.
1EBANON SANITARY DIS1RIC1
IENA SEWER UTILITY
LIBERTY SAN. PIST. 01
LINOEN SEVACE DEPT
IIIHE SUANICO SAN. DIST. «1
UVINGSTOM SEWAGE DISPOSAL PIANI
1001 SEVAGE TREAINENT PLANT
LOGANVIllE VA1ER ft SEWER UtllllT
IOMIRA SEWACE 1REA1NENT PLANT
tONE ROCK, VILLAGE Of
LOWELL, VILLAGE OF
IOTAL SEWACE TREATMENT PIANI
1 OBI III . VIllAGE Of
LUCK SEWAGE TREAIMEM1 PLANT
LUXEMBURG WASTEWAIER 1REA1NENT PLANT
LYNDON STAIION
LYONS SAN. DIST. 02
MADELINE SANITARY DISTRICT
MADISON. METROPOLITAN SEWERAGE DIS1RICT
MAIDEN ROCK, VIllAGE OF
MANAWA SEWER OEP1
MANIfOWOC SEWAGE TREATMENT PIANI
MAPLE LANE HEALTH CARE CENIER
NAPIE SCHOOL DISI NORIHUESIERN MIDDLE SCHOOL
MAPLE SCHOOL DISI-NOR1WES1ERN HIGH SCHOOL
MARATHON WATER I SEWER OEPT
MARIBEl SEWAGE INEAIMENI PLANT
DIST
SE
NW
NC
IN
SO
NC
HC
IM
SO
IN
IN
SO
IN
SO
SO
SO
SO
SO
SO
we
NW
NW
IN
NC
SE
NW
SO
we
IN
IN
IN
NW
NW
NC
IN
DESIGN
.FLOW
0.0600
0.0125
0.7500
0.0124
0.7400
0.0800
0. 1070
0.0500
0.0170
0.1250
0.0400
0.0600
0.0490
0.4320
0.3200
0.0450
0.4900
0.0570
0.0400
0.2000
0.0200
0.3650
0.4000
0.0550
0.1000
0.1520
50.0000
0.0220
0.2850
15.5000
0.0370
0.0270
0.3000
0.0500
10IAL
POINTS
130
16
12
112
70
46
130
28
146
39
26
71
15
108
40
72
120
34
23
168
16
48
193
67
27
73
4
35
too
35
9
33
44
92
37
PART 1
POINTS
0
80
10
0
80
0
80
25
0
0
0
0
0
5
0
0
0
20
5
60
25
0
0
0
0
0
0
0
0
0
PART 2
POINTS
0
0
45
0
0
IS
20
0
5
0
0
too
0
30
75
15
0
too
0
55
0
0
0
15
IS
0
0
0
50
0
PART 3
POINTS
12
32
0
36
18
6
10
14
11
36
6
8
10
19
15
6
17
6
7
15
17
17
4
6
20
7
15
23
32
23
PART 4
POINTS
0
0
IS
5
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
PART 5 1
POINTS 1
0
0
0
0
0
6
0
0
0
30
0
0
20
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
10
0
PART 6
POINTS
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
PART 7
POINTS
0
0
0
0
0
0
0
0
0
0
0
0
10
0
0
0
0
0
0
10
0
0
0
0
0
0
0
0
0
0
PART 0
POINTI
0
0
0
5
0
0
0
0
0
5
5
0
0
0
0
0
0
0
0
s
0
0
0
s
0
0
10
10
0
0
1 RECOMMENDATION BY
i MCA ENGINEER
FIX SUNKEN SIDEWALK
NO ACTION
NO ACTION
REDUCE I/I. DOME NECN. PI.
FACILITY PLAN
NO ACTION
TIME SCHDl. FOR INPRVNNT.
NO ACTION
NO ACTION
NO ACIIUN
NO ACTION
NO ACTION
NO ACT ION
NO ACTION
NO ACTION
NO ACTION
LEAKY LAGOON
ON*
NO ACTION
NO ACTION
NO ACT.ION
NO ACTION
NO ACTION
NO ACTION
NO ACTION
NO ACTION
NO ACTION
NO ACTION
NO ACTION
NO ACTION
ON*
-------
198? COMPLIANCE MAINTENANCE ANNUAI RETORT
22420
240<0
31992
30317
21377
29254
20800
30384
20842
26158
31780
2172$
22268
21083
22284
20567
31577
22063
30937
29963
32182
60381
29599
60844
20184
24686
20885
60429
24139
20991
21776
32204
28363
20249
22781
MCII lit NAME
FOR! MCCOT US ARMY
FOUNTAIN CITY SEWAGE TREATMENT PI AN I
FOX LAKE WATER POLLUTION CONTROL COMMISSION
FOX POINI VILLAGE OF
FMNCIS CREEK SEWAGE TREATMENT PI AN I
FREDERIC SEWAGE TREATMENT PIANI
FREDONIA MUNICIPAL SEWER AND WATER UTILITY
FREEDOM ELEMENTARY SCHOOL
FREEDOM WASTEUAIER TREATMENT PLANT
FREMONT SEWAGE TREATMENT PLANT
FRIESLAND. VILLAGE OF
GALESVIllE SEWAGE TREATMENT PLANT
CATS NIL IS SEWER DEPT
GENOA CUT SEWAGE TREATMENT PLANT
GENOA WATER AND SEWER OEPT
GERMANTOUN, VILLAGE OF
CinSVlUE SAN. OIST.
GILUfl WAIER AND SEWER COMMISSION
OILMAN. VILLAGE Of
GLEN FLORA, VILLAGE OF
GIENDAIE CUT OF
GLENVOOD CUT
GLIDDEN SANITARY DISTRICT
GOODMAN SANITART DISTRICT 01
GRAF ION WATER AND WASTEWAIER UTILITY
GRAND CHUTE -MENASHA WEST SEWERAGE COMMISSION
GRANION SEWAGE TREAIMENT PLANT
GRANFSIURG. VILLAGE
GRATIOT. VILLAGE OF
GREEN IAY MEIROPOLIIAN SEWERAGE DISTRICT
GREEN LAKE SEWAGE TREATMENT PLANT
GREENFIELD CITT OF
GREENGROUTN CORPORA! ION UINTERGREEN WUTP
GREENWOOD SEWAGE TREAIMENI PLANT
GRESHAM SEWAGE TREAIMENI PLANT
DIST
we
we
SO
SE
IN
NW
SE
IM
IM
IM
SO
we
we
SE
we
SE
SE
IN
NW
NW
SE
we
we
IM
SE
IN
we
NW
SO
IN
SO
SE
SO
we
IN
DESIGN
FLOW
0.5000
0.2100
0.4550
0.0700
0.2570
0.6000
0.0150
0.1772
0.1000
0.0266
0.3100
0.0900
0.2160
0.0400
1.0000
0.0300
0.3300
0.1250
0.0063
0.2620
0.1000
0.0800
2.1500
3.9000
0.0600
0. 1250
0.0500
52.5000
0.2826
0.0370
0.2210
0.1530
TOTAL
POINTS
60
14
88
25
16
88
18
4
4
101
13
0
57
9
0
0
38
32
8
ir
0
136
36
46
38
23
7
206
55
66
43
0
NA
62
97
PART 1
POINTS
0
0
0
25
5
0
0
0
0
20
0
0
0
0
20
10
0
0
5
0
0
0
5
0
20
55
PART 2
POINTS
0
0
40
0
0
0
0
55
0
0
15
0
0
0
n
0
0
0
0
0
15
40
0
0
25
5
PART 3
POINTS
40
14
5
5
a
4
21
8
30
14
6
2
8
U
40
8
8
5
40
26
8
12
a
PART 4
POINTS
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
5
5
PART 5
POINTS
0
0
0
0
TO
0
0
0
0.
0
0
0
0
0
0
30
0
0
0
0
30
0
0
PART 6
POINTS
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
PART 7 1
POINTS
20
0
10
0
0
0
0
0
0
0
0
10
0
0
0
0
10
0
0
0
0
0
0
PART a
POINTS
0
0
0
0
o.
0
0
0
0
0
0
0
0
0
RECOMMENDATION BY
AREA ENGINEER
NO ACTION
NO ACTION
NO ACt ION
NO AC1ION
NO ACtlON
NO ACTION- -FAC. PLAN. SUGG.
NO ACTION
IMPROVE O 1 N
FIX LAGOON LEAK
MONITOR CAREFULLY
HO ACTION
HO ACTION
NO ACt ION
NO ACt ION
NO ACt ION
HO ACt ION
NO ACt ION
OUtlN. Of ACTION
NO MI ION
NO ACt ION
,
NO ACt ION
NO ACt ION
MCII 1 IV PLAN
NO ACt ION
HO ACt ION
NO ACt ION
NO ACt ION
DID NOT OPERATE
NO ACt ION
CHECK NEtERStSANPLING
-------
1987 COMPLIANCE MAINTENANCE ANNUM HEPOJM
24171
35149
35459
20192
61000
24201
21121
2(210
S1212
11275
23051
36790
21270
J5«BJ
20581
2822S
24236
28339
28207
315JO
24761
28142
20231
228M
21679
24279
20010
20SOS
32085
24287
60275
21717
305)8
20486
22446
MCIIIIT NAME
HAMMOND. VIUACC Of
HANCOCK. VIUAGE Of
NARNDNf GROVE - WEE JOIN! SEWERAGE COMN.
NARIfORO SEWAGE IREAINENT PLANT
NAU6CN VIUAGE Of
HAWKINS. VILLAGE Of
NAVVARD SEWER AND WA1ER UfllltT
NA2EI GREEN SEWAGE fREAIMENT PLANT
HEAR! OF 1NE VAllEt NEIRO SEW OIST
HE Will SANI1ART UlllltV
HIDDEN MEADOWS MNP
NIGHIAND, VIUAGE
HIIBER1 UASTEWATER IREAIMENt PLANT
HIllPOINT SANITARY DISTRICt
NIUS80RO MUNICIPAl WASTE TREATMENT PLANT
NINGRAN SANITARY DISTRICT
NIXTON SEWAGE TREATMENT PIANI
NOICOME SO «1 C/0 HOWARD RICKER
HOt I AND (TOWN Of) SANITARY DISTRICT ft
HOtlANOALE VIUAGE Of
NOtMEN MUNICIPAl SEWER DEPI
HOIY fAMIlf CONVENT
INMIOON UASTEWATER TREATMENT PIANT
NORIONVIllE SEWAGE TREATMENT PIANT
HOWARDS GROVE WASIEWATER TREATMENT PIANT
HUDSON SEWAGE TREATMENT PIANT
HURLEf SEWAGE TREATMENT PIANT
HUSIISrORO SEWAGE TREAIMENT PLANT
HUSTLER. VILLAGE Of
INDEPENDENCE SEWER UTILMT
INTERLAKEN RESORT Vltl. C/0 ANVAN CORP.
IOLA SEWER UTILITY
IOWA-GRANT JOINT SCHOOL DIST
IRON NIDGE SEWAGE TREATMENT PLANT
IRON RIVER S AH It ART OISIRICI 01
OIST
we
IN
SO
SE
NW
Nil
NW
SO
IN
NC
SO
SO
IN
SO
oc
SE
we
we
IN
SO
we
IN
SO
IN
SE
we
NW
SO
NC
we
SE
IN
SO
SO
NW
DESIGN
riou
0.1540
0.4250
2.0000
0.2460
0.1180
0.1850
0.1750
5.5000
0.0513
0.0380
0.0850
0.1700
0.0105
0.5000
0.0500
0.0400
0.0250
0.2000
0.0300
0.8100
0.0000
0.5820
0.4900
0.2800
1.1000
0.4000
0.1500
0.0214
0.1660
0.1750
0.2170
0.0100
0.1170
0.0600
IOIAL
POINTS
7
0
95
98
56
8
12
8
53
156
86
14
207
0
78
0
14
184
50
70
60
45
41
30
44
62
5
145
80
10
62
28
45
83
188
PART 1
POINTS
0
0
0
0
0
20
30
0
60
60
0
80
20
15
50
0
0
0
20
0
75
55
0
0
0
5
80
PART 2
POINTS
0
50
0
0
0
80
0
0
85
0
0
50
0
20
0
0
0
0
5
0
15
0
0
5
5
25
35
PART 3
POINTS
5
5
6
8
8
17
26
4
11
8
9
8
20
18
10
30
6
10
14
12
9
5
to
18
40
23
21
PART 4
POINTS
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
5
5
0
0
0
0
0
0
5
0
0
5
PART 5
POINTS
0
0
0
0
0
0
30
0
0
0
0
0
10
0
0
0
10
10
0
50
0
0
0
0
0
0
0
PART 6
POINTS
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
10
0
0
0
0
0
0
0
0
0
0
PAR! t
POINTS
0
0
0
0
10
0
0
0
0
0
10
10
10
0
0
10
0
0
0
10
0
PART
POINT
0
s
0
0
0
0
0
s
0
0
0
0
0
0
0
0
0
0
s
0
0
0
0
0
0
0
1 RECOMMENDATION BY
1 AREA ENGINEER
NO ACTION
MONTR. REC. NODS.
.NO Ml ION
MAINTENANCE
NO ACTION
UPGRADE STARTED
ONR
NO ACTION
NO ACTION
ONR
NEW PLANT OR CONTROL ANPI
NO ACTION
ONR
NO ACTION
NO ACTION
NO ACTION
NO ACTION
REPAIR PROGRAM
NO ACTION
NO ACTION
SET UP PREV.NAINT.; VILLAGE CNR
NO ACTION
NO ACTION
IMPROVE S MAINT.
NO ACTION
NO ACTION
NO ACTION
-------
1987 COMPLIANCE MAINtENANCF ANNUAl REPORt
6037?
20788
35 IK
22217
30988
20354
31445
30830
23698
60577
20168
21016
23787
29793
25356
2)7(4
32026
60674
50682
21741
60968
60941
23817
26911
21571
21351
31682
31615
30899
J1526
22004
20397
?3850
30716
21784
MClt lir NAME
CRIVII2 SANHART DISIRICI
CROSS PLAINS WAIER AND SEWER OIHIIT
CRVSIAl LAKE SANITARY DIS1RIC1
CUBA CUT WASTEUAIER 1REAIMENT PIANI
CIIDAHV, cur or
CUMBERLAND MUNICIPAL DISPOSAL PLANT
CORIISS. vuiACE or
0*1 E S. D. NO. 1
OAllAS SEWAGE DISPOSAL PI AMI
DANE. VUIACE
DARIEN. WATERWORKS AND SEWCR SYSTEM
DARLINGTON SEWER AND WATER UMIUT
DE PERE WAS1EWA1ER IREA1MENT PIANI
DE SOTO. VUIACE Of
DEER PARK SEWAGE TREATMENT EACH It Y
DEFRME1D SEWAGE TREATMENT PLANT
DEIAHEID-HARTIAND POLLUIION CONTROL COMN.
DELIS MM! COMPANY
DHLS BOAT COMPANY WITCHES GUICN
DENMARK WASIEWA1ER TREATMENT PLANT
DEVILS MEAD LODGE
DEVI-RARA RESORT
DICKEYVILLE SEWER DEPARTMENT
OOOCEVIUE SIP
DORCHESTER WAS1E WATER TREATMENT PLANT
DOUSMAN SEWER UTILITY
DOUNSVIUE SAN. DISI. «T
DRLMNOMO SANITARY DISTRICT
DURAND SEWERAGE DEPI
EAGLE LAKE SEWER UTILITY
EAGLE RIVER LIGHT t WATER OEPt
EASI TROT. VILLAGE Of
EAU CLAIRE WASTEWA1ER IREAIHENT EACH 1 TV
EDEN. VILLAGE OF
EDGAR WASTE 1REA1MENI PLAN!
DIST.
LM
SO
NW
SO
SE
NW
we
IN
NW
SO
SE
SO
IN
we
we
SO
SO
HC
NC
IN
SO
SO
SO
SO
we
SE
we
NW
we
SE
NC
SE
we
so
NC
DESIGN
.now
0.1200
0.4500
0.0660
0.3000
0.4000
0.0120
0.0600
0.1000
0.3000
0.4340
14.2000
0.0627
0.0300
0. 1670
2.2000
0.0040
0.0040
0.5000
0.05SO
0.0200
0.1700
0.5100
0.0735
0.3500
0.0270
0.0400
0.8600
0.4000
0.4750
0.7030
16.2600
0.1500
0.1950
TOTAL t
POINTS r
113
20
92
12
15
10
141
197
43
40
126
21
32
14
163
68
24
NA
NA
109
63
WAIVED
61
64
55
20
19
27
10
IB
108
18
24
60
16
'ART 1
'OINTS
0
0
0
15
30
25
0
0
0
45
0
0
10
25
35
0
T5
0
0
0
50
0
0
PART 2
POINIS
80
0
0
0
45
90
0
10
0
30
0
0
55
0
20
50
5
0
0
0
0
50
0
PART 3 1
POINIS 1
5
10
12
11
23
40
6
14
27
8
14
14
30
6
14
21
19
10
10
28
10
6
PART 4
POINIS
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
PART 5 1
POINTS I
0
10
0
0
0
0
0
0
0
50
0
30
0
0
0
0
0
0
0
20
0
0
PART 6 I
POINIS
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
10
0
0
PART 7 i
POINTS
0
0
0
to
10
0
0
0
0
10
10
0
0
0
0
0
0
0
0
0
0
10
PART f
POINT!
0
0
0
10
0
0
5
0
0
0
0
0
0
0
0
0
0
10
0
0
0
0
1 RECOMMENDATION BY
t AREA ENGINEER
CONTINUE WEED REMOVAL
NO ACTION
MONITOR INFl. MO
NO ACTION
NO ACTION
(INT OR6. LOAD
ONR REQUIRED
ONR
NO ACTION
NO ACTION
STARTED r AC. PLAN
NO ACTION
NO ACTION
MAINTENANCE
ONR
NO ACTION
FACILITY PLAN
NO ACTION
87CMAR WAIVED
NO ACTION
NO ACTION
NO ACT 10*
NO ACTION
NO ACTION
NO ACTION
NO ACTION
NO ACTION
INVST. INDST. 10
NO ACTION
NEED CERT. OPERATOR
NO ACTION
NO ACTION
-------
1987 COMPLIANCE HAINIENANCE ANNUAl REPORt
MCM I IT MNC
DESIGN IOIAI PARI 1 PA* I 2 PARt 3 PARt 4 PARI 5 PART 6 PAR I 7 PAR I 6 RECOWENDAt 10* IT
oist.rtow points points POINIS Points POIHIS Points points points points AREA ENGINEER
20346
29126
61280
29726
23892
23914
21253
23922
23931
23949
31607
61271
20621
2395?
60623
31623
36200
21440
25976
23973
2J98I
31(11
20974
60593
35203
228(5
23990
30660
26689
36021
24023
32123
60747
78894
??489
EOGERtON MUNICIPAL OISPOSAI PlANt
EDISON ESIAfES NOfllE NOME PARK
ECC NARROR. tOUH Of
EICNO SAnilART DISIRICf » 1
lltVA SEUER UIHITT
EtR MOUND WA1ER AND SEWER OllllIT
ElLSUDRfN SEWAGE TREATMENT PI Ant
EIMUOOD SEWAGE OISPOSAI PlANt
ELROT WASIEVA1ER TREATMENI PlANt
EMBARRASS UIIUtlES
EMERALD AND GLENUDOO IOUNS S.O. NO. 1
EPNRAIN VI LI AGE
ETTRICK SEWAGE tREAtMENt PlANt
EVANSVIUE WASTEWATER TREATMENT PlANt
EVERGREEN MOB MM PK C/O COUINS ft CO RE
EMEIANO. VIllAGE Of
rAIRCNIlD. VIllAGE
fAIRVAIER SEWAGE tREAtNENt PLANT
fAll CREEK SEWAGE tREAtMENt PlANt
MIL RIVER SEWAGE TREAtMENt PlANt
FENNIMORE WAStEWAtER tREAIMENt PlANt
rENWooo vi ti AGE or
FERRVVIUE SEWAGE tREAtMENt PlANt
ririElO SANITARY DIST NO T
FISN CREEK SANITARY DISIRICI NO 1
FLORENCE MUNICIPAL SEWER SYSTEM
rONO Ml LAC WASTEWAtER IREAtMENt PlANt
rONKS NHP. KANSASVIllE
tONKS NHT>. YORKVIllE
FONTANA-VALWORTN WATER POltUtlON CONtROl COM
tOOIVItlE SEWAGE TRFAtNEHf PI Ant
roRESt junction SAN oist
lORESt SANItARV DIStRICt WO 1
tOREStVlllE SAHItARV COMMISSION
TORI AtKINSOn SEWAGE IBtAIMENI PlANf
SO
IN
IM
LM
we
we
we
we
NC
IM
we
IN
we
so
so
Ml
we
so
we
so
so
NC
we
NW
IN
IN
so
SE
SE
SE
SO
IN
we
IN
SO
0.7000
0.0189
0.0600
0.0700
0.1530
0.6600
0.0900
0.2(40
0.1500
0.0125
0.0630
0.6000
0.0200
0.0273
0.0810
0.0500
0.1549
0.1820
0.6200
0.0200
0.0(00
0.0550
0.1500
0.1090
11.5000
0.0200
0.0270
1.4500
0.0820
0.0290
0.0075
0.0800
2.7000
48
70
0
23
80
181
21
63
20
7
34
0
0
21
50
102
13
53
30
64
14
32
170
34
161
24
45
115
148
2
67
82
45
39
7*
40
30
0
55
0
0
0
0
0
0
10
65
5
0
0
40
0
.0
60
0
35
0
0
30
0
55
15
0
10
5
0
0
0
60
5
50
0
0
0
0
0
0
0
15
0
5
0
0
15
0
65
0
25
55
0
0
30
0
0
0
8
40
17
36
16
8
10
5
11
8
21
7
3
15
6
3
14
14
23
It
6
5
20
30
2
12
7
18
9
30
0
0
0
0
0
5
0
0
0
0
0
0
0
0
0
0
0
0
25
0
5
0
0
0
0
0
0
0
0
0
0
0
0
30
0
0
0
0
0
0
0
0
0
0
20
0
0
0
b
0
0
0
0
0
0
0
0
0
0
30
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
10
0
0
0
0
0
0
0
0
0
0
0
0
0
10
10
0
0
0
0
10
0
10
to
0
0
0
0
0
0
0
0
10
s
0
9
0
10
0
0
0
10
s
10
0
0
0
0
0
0
0
10
0
0
NO ACTION
NO ACTION
HO MI ION
SLUDGE HANDLING
ONR
NO ACTION
M ACTION
NO ACTION
NO ACTION
UP6RO. POND NON./GET OPttR.
ONR
NO ACTION
NO ACTION
IVAl. SAMPLING ft FLOW NONITORIN6
NO ACTION
NO ACTION
NO Ml ION
M ACTION
CERTIFY OPERATOR
INT tOO LOAD. PREV. MAIN. PROG. .OP.
NO ACTION
FAC.PIAN IN PROGRESS
NO ACTION
NO ACTION
NO ACTIONKING UPGRADED
NO ACTION
NO ACTION
COMPLY W/PERMIt LINItS
NO ACTION
PREL.TRT.EVL..FL. NOT.INt.
-------
1987 COMPLIANCE MAINIFNANCE ANNUAL REPORT
28908
21737
60330
21761
23*42
61026
603*8
297*6
204(1
22021
2190)
22136
23*69
23*65
6005*
3HOI
21601
12051
6014)
6!158
22926
31551
30821
20656
23511
2352)
26948
26808
20818
72829
31)72
23566
20915
2142)
31801
(ACII If* NAME
BOS1WICK VAUIT MOBILE HOME PK
BOWLER WATER 1 SEWER OMIIIT
BOVCEVIllE. VILLAGE
BOYO SEWAGE TREATMENT PLANT
BRANDON UTIl HIES
BRAZEAU fN S 0 *0 1
BRIGHTON OAtE CIT PK
Mill SCHOOt. RICE l«KE SCHO01 SYSTEM
BRILL ION SEWAGE tREAtMENT PI AN I
BRISTOL UMIIIT DISTRICT «1 1 IB
BRODNEAD SEWAGE TREATMENT PLANT
BROKAW SEWAGE TREATMENT PLANT
BROOKFIEID. FOX WATER POLLUTION CONTROL CTR
BROOKLYN SEWAGE TREATMENT PLANT
BROOKUOOD N S. HORWALK - ONTARIO SCHOOLS
BROWN PEER VILLAGE Of
BROMSVIUE SEWAGE TREATMENT PLANT
BROWNTOWN.VIILAGE OF
BRUCE WATER < SEWER UTILITY
BRULE SAN. OIST. »l
BURLINGTON WASIEWAIER TREATMENT PLANT
BURNETT SANITARY DISTRICT
BUTTE OES MORTS S. 0. * 1
BUTTERNUT SEWAGE TREATMENT FACILITY
CAOOTT. VILLAGE OF
CAMBRIA SEWAGE TREATMENT PLANT
CAMBRIDGE WATER AND SEWER DEPT
CAMP AMNICON
CAMPBELLSPORT SEWAGE TREATMENT PLANT
CAROLINE SANITARY DISTRICT f! STP
CASCADE VI I I OF
CASCO SEWER UTIl ITT
CASHTON. VILLAGE OF
CASSVIUE SEWER DEPT.
CA7ENOVIA, VILLAGE OF
DIST.
we
LM
we
we
so
LM
SE
NW
IN
SE
SO
NC
SE
SO
we
SE '
SO
so
NW
NW
SE
SO
IN
NW
we
so
so
NW
so
IN
SE
IN
we
so
so
DESIGN
FLOW
0.0200
0.0700
0.1200
0.0671
0.1660
0.0500
0.0100
0.0020
0.7140
0.2700
0.5000
0.0700
10.0000
0.0600
0.0070
0.0750
0.040S
0.1000
0.0165
2.5000
0.0)61
0.0105
0.0736
0.1770
0. 1265
0.34)0
0.0018
0.5)00
0.0870
0. 1672
0.0700
0.2100
0.2745
0.0450
TOTAL
POINTS
«l
3)
204
41
42
18
46
61
17
255
10
165
14
12
96
15
92
35
10
71
156
153
119
78
78
8
150
24
144
54
22
55
51
70
23
PART 1
POINTS
0
0
to
to
0
5
0
0
0
0
0
5
0
0
0
50
0
80
45
70
0
5
0
0
0
0
35
30
0
0
PART 2
POINTS
S
0
0
0
0
0
0
too
0
0
IS
10
65
15
0
7
too
S
0
0
0
too
0
100
0
0
0
0
0
5
PART 3
POINTS
36
25
6
12
It
12
10
40
4
12
40
5
11
6
9
15
34
4
8
8
8
13
8
24
17
20
6
40
7
PART 4
POINTS
0
0
10
0
0
0
0
20
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
IS
0
0
PART S
POINTS
0
0
TO
20
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
20
0
PART 6
POINTS
0
0
0
0
0
0
0
0
10
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
PART 7
POINTS
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
10
0
PART t
POINTS
0
0
0
0
0
0
0
S
0
0
S
0
0
0
5
0
0
0
0
0
0
5
f
10
0
0
0
0
5
1 RECOMMENDATION BY
! AREA ENGINEER
FACILITY PLANNING
NO ACTION
HO ACTION
NO ACTION
NO ACTION
NO ACTION
UNDER CONSTRUCTION
NO ACTION
EVAl. TRICKLING FILTER AND INFLUENT
NO ACTION
CONTROL GARAGE DISCHARGE
NO ACTION
NO ACTION
NO ACTION
NO ACTION
REPLACE riOW METER
IN FACILITIES PLANNING
NO ACTION
VERIFY CAPACITY
REDUCE I./I
NO ACTION
ONR REQUIRED
NO ACTION
NO ACTION
NO ACTION
NO ACTION
NO ACTION
NO ACTION
-------
190? COMPLIANCE MAINIENANCE ANNUAL REPORI
60020
207ii
60119
30232
40783
25348
21598
30961
22799
2340*
JA044
J1585
79700
36704
23639
30848
2?OS9
21446
32049
20702
21407
20214
2345S
22080
23443
22949
40841
21008
29882
28240
21059
20958
21300
30295
36277
MCIIIIT NAME
CECIl. VIU Of
CEDAR MOVE SEVACE IREAIHENI PIANI
CEDAR LAKE HONE
CEOMBUR6 WASTE WATER
CENTUtlA. VIM-VF Of
CNASERURG SEWAGE IREATMENT PI AN I
CRETEK SEWAGE TREATMENT PLANT
CHILI SANITART DISTRICT
CHI I TON WASH-WATER TREATMENT PLANT
CNIPPEWA MILS VASTEUATER TREATMENT PLANT
CHRISTMAS MOUNTAIN SAN DISTRICT
CHULA VISTA RESORT
CLARK COUNTY HEALTH CARE CENTER
CLAYTON SEWER DEPARTMENT
CLEAR LAKE SEWAGE TREATMENT PLANT
CLEVELAND UASTEWATER TREATMENT PLANT
CLINTON SEWAGE TREATMENT PLANT
CLINTONVILLE. CITY Of
CLOVER SANITARY DISTRICT NO. T
CLYNAN UTILITY COMMISSION
COM SEWER OEPI
COCRRANI SEWAGE TREATMENT PLANT
COLRY SEWAGE TREATMENT PLANT
COLENAN WASTEWATER TREATMENT PLANT
COir AX SEWER AND WATER UTILITY
COLLINS TRUCK SERVICES
COL DMA. VILLAGE
COLUN8US CITY OF
CONCORDIA COLLEGE WISCONSIN
CONGREGATION OF SAINT AGNES UT 11 HIES
CONSOtlDATEO KOSHKONONG S D
COON VALLEY WASTEWATER IRfAIHENI PLANT
CORNELL SEWAGE DISPOSAL PI ANT
COUNTRY ESTATES SANITARY DISfRICI
CRANOON WA1ER > SEUER UIIIIIY
OISI
LM
SE
SE
SE
NW
we
NW
we
IN
we
SO
c
we
NW
NW
LM
SO
IN
NW
SO
SO
we
NC
IN
we
LN
LM
SO
SE
SO
so
we
we
SE
NC
DESIGN
.now
0.0800
0.4200
0.0500
3.0000
0.0950
0.0800
0.3800
0.0500
0.0750
5.6100
0.0450
0.0720
0.0287
0.0400
0.2494
0.1500
0.3050
1.0000
0.0000
0.0500
0.0400
0.0720
0.3000
0.2800
0.1000
0.0090
0.0400
1.0000
0.0400
0.0720
0.4000
0.1800
0.3954
0.0250
0.2600
tOfAl
POINTS
84
14
39
105
31
35
14
132
76
16
14
32
109
141
162
145
47
130
13
140
34
16
67
22
13
0
0
6
85
80
70
13
55
125
118
PAR I 1
POINTS
0
5
0
0
0
0
0
25
70
15
0
0
5
15
0
0
0
5
0
0
0
25
15
PART 2
POINIS
0
0
5
60
0
0
0
55
0
TO
15
0
75
0
0
0
0
0
0
40
5
20
50
PARI 3
POINtS
12
34
21
6
6
2
20
2
40
12
40
0
25
6
5
32
12
5
6
40
5
10
9
PART 4
POINIS
0
0
0
0
0
0
0
0
5
0
35
0
0
0
0
0
0
0
0
0
0
0
0
PART 5
POINIS
0
0
0
to
0
0
0
0
30
10
20
0
0
0
0
30
10
0
0
0
0
0
0
PART 6
POINTS
0
0
0
0
0
0
0
0
0
0
20
0
0
0
0
0
0
0
0
0
0
0
0
PART T
POINTS
0
0
0
0
to
10
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
PART 8
POINTS
0
0
9
0
0
0
0
0
0
1
0
0
0
0
0
0
RECOMMENDATION BY
AREA ENGINEER
CHK INFl O.ROD
NO ACTION
NO ACTION
NO ACTION
MONITOR IND. OISCR.
NO ACTION
NO ACTION
NO ACTION
NO ACTION
FACILITIES PLAN
NO ACTION
ONR OR FAC. PLAN REO'D
NO ACTION
CONSTRUCTING NEW PLANT
NO ACTION
NO ACTION
NO ACTION
NO ACTION
ONR RECOMMENDED
NO ACTION
NO ACTION
-
NO ACTION
CONTROL Em SS
MAINTENANCE
NO ACTION
CONNECT TO LYONS
ONR
-------
19B7 COMPLIANCE MAINICMANCE AMNUAt REPORI
2JKI
23159
60127
2H99
20745
28053
22101
21385
2J18J
60780
60208
61077
31861
60691
6029.1
29327
2012S
'23211
31747
22144
23221
23230
60704
2222S
60232
21512
31267
31909
31381
30767
22365
27411
2)272
31852
60151
IACII llf MANE
ABBOISrotO PISPOSAl PIANI
WANS WATER AND SEWfR UfllllT
ADIll. VIII AGE
ALBANY, VI 1 1 ACE OF
AlCOMA. CUT OF SEWAGE DISPOSAL PIANI
AtlENION SANMART OISI NO. 1
INN. CUT OF MUNICIPAL UASIEUAIER PIANI
AIMA CENTER. VI 11 ACE OF
AIMENA
AIMONO VIII AGE
ALPINE VALLEI RESORT INC
ALPINE VAllET RESORT INC. (MUSIC- THEATER)
AMANI SANITARY DISTRICT
AMERICAN BAPTIST ASSEMBLY
AMERICAN MOBILE RONE COMMUNITIES
AMERICANA-WISCONSIN CORPORATION
AMERY SEWER OEPI.
AMHERSr SEWAGE TREATMENT PLANT
ANDERSON SANITARY DISTRICT 02
ANTIGO.CITY OF
APPLETON WASTE WATER TREATMENT PIANI
ARCADIA WASTE WATER TREATMENT PLANT
ARENA VI 1 LACE
ARGYLE WASTE WATER TREATMENT PLANT
ARKANSAW SANITARY DISTRICT
ARLINGTON SIP
ARPlrf. VI LI AGE OF
ARROWHEAD CAMPGROUND
ASHIPPIM SANITARY DISTRICT
ASHLAND. CITY OF
ATHENS SEWAGE TREATMENT PLANT
AIIBININDAIE SEWAGE IREAIMFNT FACILITY
AUGUSTA SEWAGE TRFATMENI PLANT
AURORA SANITARY OISIRICI 01
AVOCA. VILLAGE
OISI.
NC
NC
SE
SO
IM
SE
we
we
NW
NC
SE
SE
NW
SO
SE
SE
NW
RC
NW
NC
IN
we
SO
SO
we
SO
NC
NC
SO
NW
NC
NC
we
IN
SO
Of SIGN
.FLOW
0.2070
0.3000
0.1000
0.1200
0.7500
0.3600
0.1230
0.0700
0.1430
0.0600
0.0400
0.1000
0.0060
0.1600
0.0366
0.5000
0.5700
0.1400
0.0500
2.4700
16.5000
0.7000
0.0500
0.1000
0.0440
0.0500
0.0557
0.0259
0.0710
1.6000
0.1050
0.1200
0.3300
0.0466
0.0220
TOIAL
POINTS
22
U2
68
56
96
180
12
22
18
224
125
68
S3
51
100
32
74
100
28
31
S3
0
88
107
164
123
133
NA
153
155
33
5
16
128
48
PART 1
POINIS
0
15
0
to
60
80
0
10
0
0
20
0
0
5
25
5
60
80
0
0
0
0
0
0
20
PARI Z
POINTS
0
65
0
0
0
90
0
0
0
0
0
0
5
15
15
SO
50
30
80
100
20
0
0
80
0
PARI 3 1
POINIS 1
2
32
40
17
36
0
12
4
30
32
40
16
16
18
15
32
3
8
20
15
5
4
16
11
16
PART 4
POINIS
0
0
0
5
0
0
0
0
0
0
0
0
0
5
0
0
0
0
0
0
0
0
0
0
0
PART 5
POINIS
10
30
20
0
0
0
0
0
0
0
30
0
0
10
0
20
0
0
0
0
0
0
0
0
0
PARI 6
POINTS
10
0
0
0
0
0
0
0
0
0
0
0
10
0
0
0
0
0
0
0
0
0
0
0
0
PART 7 1
POINTS 1
0
0
0
to
0
10
0
0
10
0
10
0
0
0
0
0
0
0
0
0
0
0
0
0
0
PART 1
POINT!
0
0
0
0
0
0
0
5
s
0
0
5
p
0
0
0
10
5
0
0
0
0
0
5
0
1 RECOMMENDATION BT
S AREA ENGINEER
ONR
NO ACTION
SYSTEM, REVIEW RECOMMENDATION
'HO ACTION
NO ACTION
NO ACTION
FACILITIES PLAN
IN FACILITIES PLANNING
IM FACILITIES PLANNING
HO ACTION
HO ACTION
ONR
HO ACTION
HO ACTION
IMPROVE OM
HO ACt ION
HO ACf ION
HO ACTION
MONITOR, OPERATOR CERT.
^'
UPGRADING IN PROGRESS
IN FACILITIES PLANNING
ONR
NO ACTION
HO ACTION
ONR
NO ACTION
-------
1987 COMPLIANCE MAINIENANCE ANNUAL REPORT
MCllltr NAME
60771 RAGIET SEWER AMD WATER
29751 BAILETS NARBOR TACHI CIU8. llfC.
26891 BALDWIN SIP
20640 (At SAM LAKE SEWAGE TREATMENT PI AMI
11224 RANCOR. Vlll Of
20605 BARABOO SEUACC TREATMENT PI AMI
29131 BAANEVELO. VltlACf OF
21687 OARRON SEUACC PLANT
29651 BATFIEIO. CUT OF
28061 BEAR CHEEK VIllAGE
2S34S BEAVER DAN WASIEWAIER TREATMENT PI AM?
23SS3 BELGIUM SEWAGE TREATMENT PtAMf
61336 BEll SANITART DISTRICT NO. 1
23361 EllEVIllE SEWA6E TREA1NENT PIAMI
20419 BElNONf SEWAGE fREAIHENT KAMI
26930 BELOI1. TOWN OF
23370 BEIOI1 SEWER OTHITT
20672 iENTON IM1ER OEPT
21229 RERUN HUNICIPAl WASTEWATER TREATMENT PIANT
31313 BETHEl LIVING CENTER
60003 BIRCMUOOD. VILLAGE OF
22691 BIRNAMWOOO SEWER UTILITY
21041 BLACK CREEK WASTEWA1ER TREATMENT PLANT
23396 BIACK EARTH SEWAGE PLANT
21954 BLACK RIVER FALLS WASTE TREATMENT PLANT
21105 BIANCNAADVIllE. VILLAGE OF
3I9SO BIENKER SNERRT SAN. OIST.
20575 BIOONER WASTEWATER IREAIKENT PLANT
30805 BIOONFIELD MANOR
25400 BIOONING10N SEWAGE TREATMENT PLANT
31658 HUE MOUNDS. VILLAGE OF
23418 BIUE RIVER SEWAGE TREATMENT PLANI
60992 BlUFFVIEW ACRES. INC.
23426 BONDUEl. Vlll OF
?2I10 ROSC08EL WASIEWAIER TREA1MENI PLANT
DISI
SO
LM
we
NW
we
SO
SO
NW
NW
IM
SO
SE
NW
SO
SO
SO
so
so
so
NC
NW
IN
IN
SO
we
SO
NC
we
so
so
so
so
so
IN
so
DESIGN
.FLOW
0.4800
0.0487
0.2920
0.1200
0.1895
2.1600
0.0800
1.3730
0.2000
0.0950
3.5000
0.3600
0.0000
0.2700
0.1100
1.0000
9.5000
0.1210
1.5000
0.0150
0.8520
0.0771
0.47SO
0.1620
0.5800
0.1092
0.0300
0.8530
0.0350
0.0920
0.0720
0.0400
0.0340
0.2600
0.4650
TOTAL
POINTS
95
39
57
48
51
80
132
68
37
28
29
19
NA
28
35
46
220
18
72
94
31
97
53
30
235
193
19
112
134
26
28
60
58
109
42
PART 1
POINTS
80
0
10
25
0
0
5
0
5
10
0
0
0
40
0
60
15
45
0
0
65
80
25
35
0
0
0
0
0
PART 2
POINTS
0
5
30
0
0
75
0
0
0
0
0
0
0
100
0
0
30
10
30
0
90
35
0
65
0
0
0
25
0
PART 3
POINTS
10
34
2
16
10
24
32
8
4
5
8
10
16
30
8
12
26
32
18
30
30
28
14
34
6
18
30
34
12
PART 4
POINTS
0
0
5
0
0
0
0
0
TO
0
0
0
0
0
10
0
0
0
0
0
0
0
0
0
15
0
0
0
0
PART 5
POINTS
0
0
TO
0
50
0
0
20
10
0
20
20
20
50
0
0
0
10
0
0
SO
SO
0
0
0
0
30
30
30
PART 6
POINIS
0
0
0
0
20
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
TO
0
PART 7
POINIS
0
0
0
0
0
0
0
0
0
0
0
0
10
0
0
0
0
0
0
0
0
0
0
0
0
10
0
10
0
PART t
POINTS
5
0
0
10
0
0'
0
0
0
0
0
s
0
0
0
0
0
0
5
0
0
0
0
0
5
0
0
0
0
1 RECOMMENDATION BT
t AREA ENGINEER
NO ACTION
NO ACTION
NO ACTION
EQUIP. REPLACEMEN
NO ACTION
NO ACTION
ONR
PILOT IN PROGRESS
NO Ml ION
NO ACTION
NO ACIION
NO ACIION
NO ACTION
IN PLANS/SPECS
NO ACTION
NO ACIION
NO ACTION
NO ACIION
NVO. OVERLOAD. BT
NO ACTION
-
ONR
IN FACILITIES PLA
NO ACTION
NO ACIION
ONR
NO ACIION
NO ACIION
NO ACTION
SLUDGE MANAGEMENT
NO ACTION
T FUND
PASS POLIISNING
NN,|NG
-------
TEXAS
-------
TEXAS
PROGRAM OBJECTIVES
In September 1985, the Texas Department of Water Resources was reorganized into two agencies:
the Texas Water Development Board and the Texas Water Commission. At this time, the Texas Water
Commission was charged with the responsibility of protecting water quality in Texas. The Texas legislature
instructed the Texas Water Commission to create two new programs. One, the Mandatory Enforcement
Hearing Program, is designed to identify permittees in non-compliance with their permit limits. The other,
the 75-90% Program, is designed to identify permittees with the potential to begin violating their permit
limits in the near future. The Texas Water Commission adopted the rule for the program, 31 Texas
Administrative Code Chapter 305 "Consolidated Permits," on June 19,1986 (Exhibit 1).
The objective of the 75-90% Program is to encourage permittees to plan and construct adequate
wastewater treatment capacity to meet existing and future needs. By ensuring that facilities have adequate
flow capacity, the problem of hydraulic and organic overloads which affect wastewater treatment and
effluent quality can then be prevented.
PLANNING PROCESS
The Texas Water Commission planned its 75-90% Program as an expansion of ideas and programs
already in place in the State. For example, the rule which the Texas Water Commission adopted to
initiate the program is based on rules in place near Houston at the Lake Houston Watershed to protect
that source of drinking water from pollution from the rapid industrial growth the area experienced in the
1970's. The Texas Water Commission decided to base its program on facility design flow because their
permit system already requires the facilities to submit their daily average flow to the Commission on a
monthly basis. The Texas Water Commission determined that the information generated by this
requirement could create an efficient and inexpensive early warning system to alert facilities of the need to
1
-------
plan for necessary expansion. Finally, the Texas Water Commission developed a tracking system to
determine which facilities exceed either 75% or 90% of their design flow. The tracking system was
developed by fine tuning existing computer programs for the mainframe database of self-reported flow
data.
The Texas Water Commission decided that compliance with the rule should be mandatory for all
permitted facilities so that all the facilities receive equal treatment. Currently only facilities which apply
for and receive a waiver are exempt from the rule's requirements.
The Texas Water Commission encountered very few problems in planning and designing its 75-
90% Program.
PUBLIC OUTREACH
Because the program is an extension of existing programs, the Texas Water Commission did not
actively solicit the participation of the permitted facilities in program development. The regulated
facilities and the public had the opportunity to comment on the proposed rule in the standard comment
period.
75-90% PROGRAM DESIGN
The 75-90% Program is based on self-reported flow data submitted by permittees on a monthly
basis. A computer program identifies those municipal facilities that exceed 75% or 90% of the permitted
flow for three consecutive months. The resulting data is reviewed by the program coordinator who sends
computer-generated letters to facilities nearing their maximum permitted flow (Exhibit 2). Each letter
contains the flow data for the three months that exceed 75% or 90% of permitted flow, relevant excerpts
from the rule, an explanation of how to comply with the rule, and an explanation of who is eligible for a
waiver of the requirements and how to apply for one.
-------
Although the Texas Water Commission acknowledges that the self-reported flow data may not be
entirely accurate, they believe that this program has actually improved the quality of data that the
Commission receives. For example, many of the facilities that have been issued a warning letter discover
that their flow meters are incorrectly calibrated. Once this type of problem is resolved, the facility is able
to report more accurate data to the Commission. The Texas Water Commission does not believe
intentional mis-reporting of data is a problem due to the existence of strong deterrents.
At 75% of permitted flow, the 75-90% Program requires a permittee to initiate engineering and
financial planning for expansion and/or upgrading of the facility. At 90% of the permitted flow, permittees
are required to obtain necessary authorization from the Texas Water Commission to begin construction of
the planned expansion and/or upgrade. In both cases, the permittee must provide information about any
coun, Texas Water Commission, or EPA order requiring expansion or upgrading of the present treatment
facilities which the facility is currently under, along with projected dates for commencing construction.
Likewise, the permittee must submit planning information and anticipated dates for construction if the
facility is pursuing any engineering and financial planning for expansion and/or upgrade on its own. At
90% of the permitted flow, the permittee must submit dates for any necessary permit applications in
addition to the requirements described above. In both cases, the permittee may be exempt from the
requirements if granted a waiver.
A facility may be granted a waiver of the requirements if the planned population to be served or
the quantity of waste produced is not expected to exceed the design limitations of the treatment facility. If
a facility chooses to apply for a waiver, it must submit an engineering report supporting its claim to the
executive director of the Texas Water Commission. An application for a waiver must include:
the estimated percentage of flow contributed by industrial, commercial, municipal, and residential
users;
-------
the projected 30-day average influent flow rate to the treatment plant at the permit expiration date'
based on population projection, anticipated addition and/or withdrawal of industrial, commercial,
and/or municipal users over the duration of the permit;
the 30-day average influent 5-day Biochemical Oxygen Demand and Total Suspended Solids
concentration for each of the past 12 months;
the number of unauthorized discharges (bypasses) from the sewage treatment plant for the past
year, their estimated quantity and duration, and the circumstances surrounding each bypass;
a schematic of the treatment plant showing its layout, including the dimensions and design
capacity of each treatment unit;
the number of excursions for the past 24 months from the permitted parameters set forth in the
permit;
the age of the collection system and treatment plant;
any sewer system evaluation surveys (SSES) and/or infiltration and inflow (I/I) studies conducted
during the past five years; and
any future plans for the expansion or rehabilitation and/or new construction including a timetable.
To be valid, the waiver must be in writing and signed by the director of the water quality division of the
Texas Water Commission. A waiver of the requirements of the 75-90% rule is reviewed upon the
expiration of the existing permit
-------
A response to the warning letter is required within 90 days of the date of the letter. The program
coordinator tracks both the date of the initial letter and the response letter and either ensures that a
waiver request contains the necessary information and is approved or denied, or tracks the milestone dates
indicated in the permittee's response. If the program coordinator does not receive a response to the letter
within 90 days, a second notice letter is mailed and the permittee is given 30 days to respond. The
appropriate Texas Water Commission District Office is then notified if no response is received to a second
letter at a facility exceeding 75% of flow capacity. The District Office usually discusses this matter with
the permit holder at their next regularly scheduled district inspection. If a facility exceeding 90% of flow
capacity does not respond to a second letter, the permittee is referred to the enforcement unit with the
request that formal enforcement action be initiated based on failure to comply with the rule. The
enforcement unit may then call in the permittee for a meeting and place the facility under an order for
corrective action.
RESOURCE INFORMATION
The 75-90% Program required minimal new funding. The State provided the salary for one full
time employee who is responsible for tracking the facilities, sending the warning letters, and tracking the
responses. The current program coordinator has approximately eight years of experience with the Texas
Water Commission and has spent approximately half of that time working in the Wastewater Enforcement
Section.
PROGRAM EFFECTIVENESS /
Since 1985, the Texas Water Commission has identified and notified at least 357 permittees in
non-compliance with the rule. Of these 357 permittees, 46 are currently being tracked through a
previously issued enforcement order, 106 have complied with program requirements; and 205 are currently
being tracked in the 75-90% Program by the program coordinator. 49 of the 205 permittees being tracked
in the program have requested a waiver, and the remaining 151 are in some stage of plant and/or
-------
collection system planning or construction. Formal enforcement action has only been requested against
five permittees lor failure to comply with the rule. The Texas Water Commission is very pleased with the
high rate of compliance from permit holders.
In the first year of the program an average of twenty letters per month were sent out to facilities
at 90% of design flow capacity (Exhibit 3). This rate has since dropped to less than ten letters per month,
although recent severe weather and flooding are expected to increase the number of facilities near their
design flow capacity. This program is considered to be a success as a result of the decreasing number of
warning letters and the small number of requests for formal enforcement action.
For more information on the Texas 75-90% Program, contact:
Ms. Jennifer Sidnell
Chief, Wastewater Enforcement Section
Texas Water Commission
(512) 463-8207.
-------
EXHIBIT 1
-------
Excerpt from
31 Texas Administrative Code Chapter 305
"Consolidated Permits"
adopted by the Texas Water Commission June 19,1986
f305.12f. Additional Standard Posit Condition* for waste
Discharge Permits* Whenever flow measurements for any sewage
treatment facility in the atate reaehea 75 percent of the per-
mitted average daily flow for three consecutive month*, the
permittee must initiate engineering and financial planning for
expansion and/or upgrading of the wastsvater treatment and/or
collection facilities. Whenever, the average daily flow reaches
90 percent of the permitted avenge dally flow for three consec-
utive months, the permittee shall obtain necessary Authorisation
from the Texas Water riimiiisiiin to ccmeance construction of the
necessary Additional treatment and/or collection facilities. Za
the case of a wastewater treatment facility which reaehea 75
percent of the permitted average flow for three consecutive
months, and the planned population to he served or the quantity
of waste produced is not etperfert to exceed the design limits*
tions of the treatment facility, the permittee win submit an
engineering report supporting this claim to the executive direc-
tor. Zf in the judgment of the executive director the population
to be served will not cause permit noncompliance, then the
requirements of this section may be waived. To be effective, any
waiver must be in writing and signed by the director of the water
quality division of the Texas water ri-mmlislnii, and such waiver
of these requirements will be reviewed upon expiration of the
existing permit, sjowever^ any such waiTer snail not be
interpreted as condoning or excusing any violation of any permit
parameter.
-------
Letter Sent at 75% of Permitted Flow
TEXAS WATER COMMISSION
8. J. Wynne. III. Cu.jr. '. - .. ' John J. V.y. 0,- C..UB^
John E. 8tnh*««. C-«-v«,;0r,er ' Mich««l E. F*W. Ch,,r i,Mf..,,
Cliff Johnson. 0,1-!-sjT-fr ' Brcncb W Foster. C.-.«- C><"
Altani
April 23, 1990
Dear Permittee:
Failure to plan and construct adequate wastevater Ueauuaul capacity to rest
existing and future needs is a major factor loading to hydraulic and organic
overloads affecting wastewater tzeataant and effluent quality. The Toas water
CDoaission (TWC), realizing this to be a aajor preblev affecting permit ccqpliansa,
prceulgated rules which were felt to be naceeeary in order to preserve and
the quality of the stata water
on Juna 19, 1986 the Texas water Ccnnisaion adopted 31 Texas Adsinistrativ* cede
(TAQ Gapter 305 entitled "Oavolidated aaraits". Section 305.126 states, in
for any SBMBQB tzeetDsnt facility in
75 percent of the pemLtted average dally flow for three
the penaitbae Bust initxaba engineering and financial planning
for expansion end/or * yjfl ** ^fj of the vesttMstbar ttearxsnt and/or collecticn
f«BiIit1s«". section 305.126 further states, "In the cese of a vastsuater
v^US3ss*eshMBians» T^B> aiSa^aveM^v^ % %> BjA0]SSB>BiaBvvB> j^pjsisipiBS»eBSiSipa6 es»F sjses' ^BBBB* T^BBBI ^MS* %> ^BjABBBaeB^w^ v&
facility, the penaittse win subsit an engineering report supporting this clai» to
To be effective^ any reiver
QRsBS^SkSl^Q^ OJ3^1HOB Of?
BTCS will be reviewi
. ._r, any such weiver shall not be interpreted
any violation of any pendt
In order to iapleMnt Caaptsr 305 cited above, a review of your wasteuater
uealusuit facility flow records was conducted for the tine period 09/1S69 tnrougn
07/1989. self acnitoring report records show that the daily average flov reached
or exceeded 75% of the design capacity (permitted daily averege flow) of the
westsMeter treataant plant for each of the three norths based on the following
information:
Parait water MQ0010396-OOI Parnitted Rsported
~~~~
05/1989 0.400000 0.344000
06/1969 0.400000 0.445000
07/1969 0.400000 0.337000
-------
Please read the following ccnpletely and then answer the appropriate questions
concerning your wastewatar treatment 'facilities. Should you have any questions
please feel free to contact Ms. Jan sills of the wastewater Biforcmmt Section at
(512)475-2185.
1. Are you currently under a Court, TWC or EFA order requiring you to
expand/upgrade your jjiuumir. treaUuatl facilities? yes/no
If you answered yes, please provide information including projected dates for
expanding/upgrading facilities.
2. If you answered no to question #1, are you at this «<« pursuing engineering
and financial planning for expansion and/or upgrading of the wastewater treatment
and/or collection facilities? yes/no
If your answer is yes, please explain, providing tiae schedules for securing
funding and schedules for * Emitting artJimii.ia.te engineering plans to the TWC or
other state agencies for approval.
3. If you answered no to question #2, you are required to initiate financial
and engineering planning for expansion and/or upgrading of the wastewater treattntnt
and/or collection facilities provided you do not seek a waiver as provided in the
rules. Should you not seek such a waiver, please provide a detailed plan with »»*»
schedules for cenplying with this requirement. Should you choose to seek a waiver
front the renjuireusaiLs of this rule, you are required to submit an engineering
report to the Texas Mater Coaaission which supports the claim that the planned
population to be served or the quantity of waste, produced will not cause permit
rcncccpliance. This report shall include, at a mlnlmm, the following information:
a. estimated percentage of flow giiLuhifsd by industrial
ii
,
municipal (schools, convention centers, etc.) and residentxal
b. yiojectsd 30-day average influent flow rats to tat tieausm. plant at the
permit expiration date, mis figure to be liesed on, but not limited to,
the FT'lTM*"* projection, the anticipated addition and/or withdrawal of
any industrial, "T*" ** and/or nnicipel users to the service area over
the duration of the permt:
c. 30-day average influent 5-day Bicchenical Cfcyojen Dsaend and Ttital
Suspended Solid* calculation for each of the past 12 norths;
d. nuabar of unauthorized discharges (bypasses) from the
plant for the past year, their estimated quantity and duration, and the
surrounding each bypass event?
ic of the CieaUiMit plant showing its layout. This should also
include the dimensions and design volunetric capacity of each
unit;
-------
f. ruttoer of excursions for the past 24 months fron the permitted parameters
set forth in the permit;
g. age of the collection system and treatment plant;
h. any sewer system evaluation surveys (SSE5) and/or infiltration and inflow
(I/I) studies conducted during the past five years; and
i. future plans for the expansicn/rehabilitation and/or construction of any
new facilities including a tiaetable.
Please send your written response to the Westawetsr Qrforaenent Section, Ttscas
ttater Comission, Attention, m. Jan Sills, P. 0. Box 13087, Capitol Station,
Austin, Taam 78711, and to the apiaropriate Oustzict off1nt» within 90 days after
the date of this letter*
Sincerely,
Jennifer sidnell. Chief
Nastsweter EJrforoenent Section
Meter Quality Division
TGR
cc: TWC - SSI, Deer Park
-------
letter Sent at 90% of Permitted Flow
TEXAS WATER COMMISSION
B. ». Wynne. III. Chaif-w T ~,\- John J. V*,. C»nf.v C«i:-v
John E. Birdw*H. Cv*-*ir".« . Mkhatl E. Fitid. C-« H«a::-.;< £, :-
Cliff Johiwon.C.<'*>:w . Brcnd* W. Fotttr. C- ? C «-
Btinke. Ext'cu'iv* Oiwo''
January 13, 1990
Dear Permittee:
Failure to plan and construct adequate wastnwatar treatment capacity to nest
existing and future needs is a major factor leading to hydraulic and organic
overloads affecting wastsMter treatment and affluent quality. The Texas water
Coonission (TVJC), realizing this to be a nejor problem affecting permit
compliance, promulgated rules which were felt to be necessary in order to
and protect the quality of the stats %«ter
on June 19, 1986 the Texas Hater Oanission ».1r,|,rt.»1 31 Ttocas Mtainistrativ*
(lag adapter 303entitl«d "Consolidated Permits". Section 303.126 states, in
90 pKCBnfe of
V%1 tffvsje^etft w^N%1 **4»^ ^^p*
p
ts in writing and siy»d by
effective, any
qUftlity dfcVU&On Of ~UP IVJPJV »^WPT \ja^fiMmuan mm* mm mmww* w* ULKBJB
iei|iiiemeiili will be lasieiBBl upon expiration of the existing permit. Bouever,
any such vedbtee? shell not be iiiLei.ta.stsd as condoning or sxcusing any violation
of any panit
in order to implement Chapter 309 cited above, a review of your vastsueter
treatment facility flow records was conctoted for the Uas period 01/89 through
03/1969. Your self scnitcring report records show that the daily average flow
reimsrt or exosedsd 90% of the design capacity (permitted daily average flow) of
the westSMstsr Ueseuant plant for each of the thras months based on the
following infornation:
Permit Number NQ00102S9-008 Permitted Reported
01/19*9 .750000 .733000
02/1919 .750000 .726000
03/1919 .750000 .698000
-------
Please read the following completely and than 'answer the appropriate questions
concerning your wastewater treatment facilities. Should you have any questions
please feel free to contact Ms. Jan Sills of wastewater Enforcement Section at
(512)475-2185.
l. Are you currently under a Court, iwc or EFfV Order requiring you to
expand/upgrade your praamt. treatment facilities? yes/no
If you answered yes, please provide information including projected dates for
submitting any necessary permit application and dates for comaaneing construction
to expand/upgrade your UeaUuauL facilities.
2. If you answered no to question II, are you at this tine pursuing engineering
and financial planning for ejqpansion and/or upgrading of the wastewater treatment
and/or collection facilities? yes/no
If you answered yes, please provide infoaaation including yrujm-Led dates for
submitting any necessary permit applications and anticipated dates for connencing
3. If you answered no to question 12, yon an required to obtain necessary
authorization rnBB the Texas water Comvission to conncnce ^ a'i«»im^^<^ of the
necessary additional traaOuariL and/or oollertion facilities whan the average
daily flow reaches 90 percent of the permitted average daily flow for three
consecutive months provided you do not seek a waiver as provided in the rule.
Should you not seek such a waiver, please provide a detail** plan, with tin
schedules for complying with the requirement. Should you choose to seek a waiver
fron the requirements of this rule, you are required to sueeut an engineering
i ^wrt to the Tews water Con&issxon which ^m^mxs the <^i*^*» that the planned
population to be served or the quantity of vast* produced will not cause permit
This report shall include, at a minioun, the following
a. estimated percentage of flow contributed by industrial, oraiinaznnl,
ipT^r^l (school*, convention centers, etc.) and residential users;
b. projected 30-day average influent flow rate to the Uaaaanit plant at the
pewit ejqjiration date. This figure to be based on, but not Ijjiritart to,
the pnpiliitl*"* projection, the anticipated addition and/or withdrawal of
any industrial, "vni1 M and/or Timi"?!*1 UMTS to the service area over
the duration of the pandit?
c. 30-day average influent 9-day Bicx*eadcal oxygen Demand and Total
Suspended Solids concentration for each of the peart 12 norths;
d. number of unauthorized discharges (bypasses) from the sewage treatment
plant for the past year, their estimated quantity and duration, and the
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e. schematic of the treetnent plant showing its,layout. Ibis should also
include the diaensicns and design volumetric capacity of each treatment
unit;
.f. nunter cf excursions for the past 24 months frcn the permitted paraneters
set forth in the permit;
g. age of the collection system and treatment plant;
h. any sewer system evaluation surveys (SSE5) and/or infiltration and inflow
(I/I) studies conducted during the pact five years; and
i. future plans for the expansion/rthabilitaticn and/or construction of any
new facilities including a timetable.
Please send your written response to the flaetSMtter Btfccoomit Section,
Attention: !» Jan SHlsf lfca» Hater ccaniaeicn, P. 0. BDK 13087, Capitol
Station, Xustin* Iteeee 7V711, and to the appropriate District office, within 90
days after the date of this letter.
Sincerely,
Jennifer Sidneil, Chief
Wasteuerter Btforcement Section
Mater Quality Division
TH
oc: TWC - SSI, Houston
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EXHIBIT 2
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-PART 5: ULTIMATE DISPOSITION OF SLUDGE
A. irfiat is final disposition of sludge from your treatment plant?
If sludge is not land applied, go to Part 6.
3. If land applied, is there plant cover on the site?
Yes (Complete question C.)
_____ No (Complete question 0.)
C. What type of cover is on the site?
_____ Crops consumed by animals whose products are consumed by humans.
(Complete Question D.)
_____ Crops that are directly consumed by humans.
(Complete Question E.)
___ Neither directly nor indirectly consumed by humans.
(Complete Question 0.)
D. Does your treatment plant have the capability of meeting the sludge disposal requi-e
ments of 4Q CFR Part 257 Appendix II for providing Processes to Significantly Reduce
Pathogens (PSRP)?
Yes 0 points
___No»»««.....50 points
What process 1s used? _,__________--__.
Go to question F.
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10
E. Does your treatment plant have the capaoility of meeting the sludge a:soosa!
requirements of 40 CFR.Part 257 Appendix II for providing Processes to Fu-:~2
Reduce Pathogens (PFRP)?
Yes 0 Points
No«..50 Points
What process is used?
F. Does tne site have a Groundwater Discharge Permit?
Yes 0 Points
No 50 Points
TOTAL POINT VALUE FOR PART 5
Enter this value on the point calculation table on the last page.
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11
PART 6: LANOFILLINfi OF SLUDGE
A. Does your facility have
(Circle the appropriate
3 or more
24-35
12-23
6-12
less than 6
years
months
months
months
months
access to sufficient land disposal sites for:
point total)
* 0 points
10 points
« 20 points
« 30 points
50 points
B.t If disposal by a landfill, is the landfill registered and has a Groundwater Discharge
Plan been submitted?
Yes 0 points
No 50 points
TOTAL POINT VALUE FOR PART 6
Enter this value on the point calculation table on the last page,
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12
Part 7: NEW DEVELOPMENT
A. Please provide the following Information for the total of all sewer line extensions
which were installed during the last calendar year.
Design Population; Design Flow: MGD Design 8005:
3. Has an Industry (or other development) moved into the community or expanded product-
in the past year, such that either flow or pollutant loadings to the sewerge system
were significantly increased (10-201)? (Circle One)
.No « 0 points; Yes 15 points
C. Is there any major development (industrial, commercial, or residential) anticipated
in the next 2-3 years, such that either flow or pollutant loadings to the sewerage
system could significantly increase (Circle One)
No * 0 points; Yes * 15 points
0. Add the point values circled In B and C and enter the sum below.
TOTAL POINT VALUE FOR PART 7
Enter this value on the point calculation table on the last page.
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13
i^vm
PART 8: OPERATOR CERTIFICATION AND TRAINING
(Reference: New Mexico Water Quality Control Commission Regulation as
amended November 25, 1988, P.art 4, Section 4-207.)
A. Responsible person-in-charge of operation per shift.
SHIFT:
NAME: ____ TELEPHONE I:
CERTIFICATION i: , LEVEL:
LEVEL OF CERTIFICATION REQUIRED
SHIFT:
NAME:__ ; TELEPHONE I:
CERTIFICATION I; LEVEL
LEVEL OF CERTIFICATION REQUIRED,
SHIFT:
NAME: ; TELEPHONE I:
CERTIFICATION I: LEVEL
LEVEL OF CERTIFICATION REQUIRED
8. Operations and Maintenance Staff.
TRAINING
CERTIFICATION CREDITS I
NAME; TITLE: LEVEL 4 NUMBER 36 MONTH!
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14
C. Staffing identified in 0AM.Manual.
TYPE/TITLE: NUMBER OF EACH
. TOTAL^
COMMENTS:
0. Points determination for operator certification and training.
Circle the appropriate point totals below.
a. Certification level for responsible persons in charge:
Meets or exceeds required level. » 0
Below required level. 30
b. Training credits for last 36 months:
All staff has 2. 30 credits 0
Some staff < 30 credits
but all staTf has 2. 10 credits 15
One or mrt staff has £ 10 points 30
c. Staffing for wastewater treatment system:
Equals or exceeds OIN Manual reeonmtndatlons 0
No 0AM Manual 3°
Less Than 0AM Manual recommendation * 60
d. TOTAL POINT VALUE FOR PART 8
Enter this value on the point calculation table on the last page.
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PART 9: FINANCIAL STATUS
List your annual 04M costs, replacement costs, debt service costs t-a-nino costs
and revenue for wastewater and debt service. .,
Annual Cost
0AM: $
Replacement: S
Debt Service: |_
Training: J_
Wastewater Revenue: S
Debt Service Revenue: S
B. Are the funds for wast ewater treatment facilities separate from other conraunity
funds? If no, explain.
C. Are all users or user classes charged based on the proportionate share?
(Circle One) Yes No
If not, why not?
0. Are the equipment replacement funds In a segregated account? (Circle One) Yes
(Equipment replacement, such as motors, pumps bearings etc., for the useful life
of the treatment facility).
Equipment Replacement Fund
Beginning Balance: S Pitt:
Additions: « $
Disbursements: S
Ending Balance: S Ditt:.
E. What financial resources do you have available to oay for your wast ewater improvement
reconstruction needs? (excluding routine maintenance replacement mentioned in 0
above)
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16
PART 10: SUBJECTIVE EVALUATION
A. Describe briefly the physical and structural conditions of the treatment facilities
8. Describe the conditions of the collection/conveyance system including lift stations
(i.e. age of sewers, infiltration/inflow etc.)
C. What sewerage system improvements does the community have under consideration for
next 10 years?
0. what was the theoretical design life of the plant and what do you believe is the
remaining useful 11ft of tht wastewater treatment facilities?
E. Uhat problem, 1f any, have been experienced over the last year that have threatened
collection or treatment of wastewater
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17
F. Is your community presently involved in formal planning for treatment facility
upgrading? If yes, describe;
G. How many times 1n the last year were there overflow or backups at any point In the
collection system for any reason, except clogging of the service lateral connection?
Times
H. Does your treatment system have a written operation and maintenance program including
a preventive maintenance program on major equipment item and sewer collection
system? (Circle one) Yes. No. If yes, describe;
I. Does this preventive maintenance program depict frequency of intervals, types of
lubrication, types of repair and other preventive maintenance tasks necessary for
each piece of equipment or each section of sewer? (Circle one) Yes No
J. Are these preventive maintenance tasks, as well as equipment problems, being
recorded and filed so future maintenance problem cm be assessed properly?
(Circle ont) Yes No
K. How many tlMS has the operator-ln-charge attended the State of New Mexico
certification exa* sessions In the last two veers? times
L. What portion of the continuing education exptnsts of the operator-in-charge were paid
for by the ptmrttttt (minic1 pal 1ty) ?_ by the operator?
What percentage of the wastewater budget 1s dedicated for training?.
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18
M. Is there a written policy encouraging continuing education and training fo
treatment plant employees? (Circle One) Yes No
Explain Policy: J_
N. Describe any major repairs or mechanical equipment replacement that you made in t
last year and include the approximate cost for those repairs. Do not include majo
treatment plant construction or upgrading program.
0. Any additional comments? (Attach additional sheets 1f necessary.)
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19
POINT CALCULATION TABLE
Fill in the Values from parts 1 through 8 .in the column below. Add the njnoers
in the left column to determine the IMPAC point total that the wastewater syscem
has generated for the previous calendar year.
Actual Values
Part 1
Part 2
Part 3
Part 4
Part 5
Part 6
Part 7
Part 8
points
points
points
points
points
points
points
points
Maximum Possible
80 points
350 points
40 points
100 points
150 points
100 points
30 points
120 points
TOTAL
points
970 points
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EXHIBIT 3
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COMBINED TOTAL OF 75-90% LETTERS MAILED
(By Month)
100
90
T T
DEC *M JAN WIU
1 I
>!**» API W MAW JUN W JULW AUGt» 8W OCTWNOVM DEC1» MN*M FKB'MMAft'M
TOTAL 75% 90%
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NEW MEXICO
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NEW MEXICO
The State of New Mexico, with assistance from the U.S, Environmental Protection Agency (EPA),
has recently implemented a pilot program to assist communities with publicly owned treatment works
(POTWs) to stay in compliance with their pollution discharge permits. The pilot program is called
Improving Municipal Performances by Addressing Capacity (IMPAC) and was started at the end of 1989.
This case study will provide some insights into the process used to plan and coordinate the program, the
components of the program, and resources needed to implement the program.
PLANNING PROCESS
As the result of a number of factors, New Mexico had identified a major shortfall in available
financing for POTW needs in the years 1995-2000. During these years, nearly all of the POTWs in the
State will reach the end of their design lives. As POTWs reach this point, communities will be in need of
several hundred million dollars to upgrade these facilities. Construction grants from the Federal
government, which have been the principal source of funding for POTW construction, will be phased out
by then and State loan repayments will still be too small to make up the shortfall.
New Mexico's Environmental Improvement Division (EID) and EPA began working together in
mid-1989 to develop a pilot program that would help avert this problem. EPA was aware of a program
designed by the State of Wisconsin to extend the design life of POTWs (for further information, see
Wisconsin's case study). Using Wisconsin's Compliance Maintenance program as a model, EID and EPA
developed New Mexico's IMP AC program. At this time, the IMP AC program is a pilot program, and no
decision has been made yet on whether to make it a permanent program.
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The goals of IMPAC are to:
protect the Federal, State, and local governments' investment of approximately $450
million in the State's POTWs; and
protect public health, and ground and surface water quality through assisting communities
with planning for long-term compliance with discharge permit requirements.
To achieve these goals, EID developed the following four objectives of the IMPAC program:
identify facilities that are approaching their treatment capacity,
initiate planning modifications or additions necessary to maintain compliance;
increase the useful life of POTWs by identifying and correcting performance limiting
factors; and
minimize municipal funds necessary to maintain POTW permit compliance.
The State did not need to seek new legislation for the program for a number of reasons. First,
IMPAC is only a pilot program. Second, the State did not need any new enforcement authority since
IMPAC is purely a voluntary program. Third, EID sees its role under the program as consistent with its
other missions.
A critical part of the planning process involved gathering officials from EID and EPA to develop
the State's program. Staff from both agencies gathered to formulate a plan and develop the components
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of IMPAC. EID's Surface Water Quality Bureau assigned the lead role for formulating IMPAC to their ''
Wastewater Construction section. The Bureau Chief of this section gathered his staff as well as Bureau
Chiefs and staff from the Facility Operations section, which is responsible for providing technical
assistance to communities, and the Surface Water Section, which is responsible for administering the
State's NPDES program. The Wastewater Construction section also invited a representative of New
Mexico State University's Utility Operator Training Program to participate. The Utility Operator Training
Program provides on-site technical assistance to POTW operators at no charge, and is often requested by
EID to intervene in cases where the State feels its presence may exacerbate the situation.
These State officials, together with EPA regional staff, revised the questionnaire that Wisconsin
developed to identify the performance and operating condition of its POTWs (Exhibit I). New Mexico,
like Wisconsin, planned to use the questionnaire as an early warning system to gather information and
screen those POTWs most in need of assistance. State officials, with assistance from EPA, also developed
a schedule for implementing the program and planned a strategy to communicate the IMPAC program to
communities with POTWs.
PUBLIC OUTREACH
EID felt that an informal, personalized public outreach strategy was the best way to inform the
relatively few communities in the State with POTWs about the IMPAC program. The State organized a
one-day workshop on the program and held them in four separate regions of the State to accommodate
community officials. The State sent out letters of invitations addressed to the mayors of approximately 75
communities urging them or the city manager or public works director, along with their POTWs chief
operator to attend one of the workshops. Along with the letter of invitation, EID also sent the IMPAC
questionnaire soliciting performance and operation information on the community's POTW.
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In addition to inviting community officials, EID also invited the Municipal League, an association
that represents the communities in the State, to the workshop. This was done in an effort to gather the
League's support for IMP AC and to use its influence with the communities to encourage their
participation with the program. BID also disseminated information about IMP AC and the workshops
through New Mexico State University's Utility Operator Training Program's newsletter in an effort to
further target plant operators and elected community officials.
Since participation in the IMP AC program as well as the workshop is voluntary, the State
encouraged attendance at the workshops by informing community officials in their invitation letters that all
municipal officials that attend the workshop will receive, free of charge, a set of POTW operations
manuals valued at over $100. EID also followed up the letters of invitation with phone calls to those
communities that had not yet responded. EID made a point to inform communities that information
obtained from the questionnaire would not be used in any new enforcement actions that would not have
been taken without that information. This was done to calm any fears that may have kept community
officials from attending the workshops.
At the workshops EID and EPA explained the goals and the expected results of the IMP AC
program and discussed the successes of the Wisconsin program. EID and EPA then facilitated a
discussion period which allowed the community officials to ask questions and give feedback. After the
general presentations, EID walked the community officials through each step of the questionnaire. The
community officials were asked to bring the necessary information with them to complete the
questionnaire, bat EID also had its data bases available to provide any missing information. The
workshop then continued as long as community officials sought assistance in completing the questionnaire.
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IMPAC PROGRAM DESIGN
As mentioned above, the IMPAC Program is a voluntary program for municipalities. The State
cannot force communities to submit any additional information on the performance of their POTWs. BID
uses the voluntary aspect of the program as a selling point, encouraging community participation without
the threat of retribution. EID is confident that its longstanding and intimate knowledge of all the
POTWs' operations will compensate for the lack of mandatory participation in the program.
The major component of the program is the questionnaire distributed to communities (Exhibit I).
The questionnaire acts as an early warning system, gathering information from community officials on
performance trends and the physical conditions of their POTWs. The purpose of the questionnaire is to
provide EID with readily retrievable data, in a centralized data source, on a variety of indicators of
conditions at POTWs. These indicators cover a number of items including:
monthly figures on influent flows and BOD loadings;
effluent quality (e.g., mg/1 of nitrate-nitrogen);
age of the POTWs and type of treatment method;
number of sewerage system bypasses;
sludge management plans and treatment capacity,
development pressures in the community,
operator training and certification;
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financial status; and
subjective questions on POTWs' conditions and plans for improvements.
The State asks POTW officials through the questionnaire to compare their data on influent flow
and BOD loadings to the levels the plant was designed to handle and to compare their effluent quality
data to the limits specified in the plants' discharge permits. The questionnaire generates point totals for
the number of exceedances of these indicators as well as point totals for responses to the other indicator
questions. Generally, POTWs with higher overall point totals have more serious performance and
operation problems than POTWs with lower points. BID uses the point totals and other data obtained
from the questionnaire to identify communities with POTWs that need special attention.
The State borrowed many of the indicators that it uses in the questionnaire from Wisconsin's
Compliance Maintenance program. EPA encouraged the State to use Wisconsin's indicators where
appropriate. The State concurred, feeling that these indicators provided the best representation of the
engineering and financial performance of POTWs. The State also used the effluent quality indicators since
these track with the water quality indicators used in the discharge permits. This allows the State to
incorporate POTWs' compliance records into the screening process. EIO revised some indicators from
Wisconsin's questionnaire based on conditions specific to New Mexico, and also debated and changed the
relative weighting that various indicators have on the overall point total
The same EID and EPA staff members that were involved with planning the IMP AC program also
reviewed the completed questionnaires. In selecting the communities for follow-up assistance, State
officials used point totals on the questionnaire as well as their own best professional judgment. This was
necessary because the review panel found that many of the communities with the highest point totals were
currently addressing their problems and would have the situation corrected in less than a year. Therefore,
-------
in addition to a high point total on the questionnaire, the panel added criteria that considered whether
communities were already under an enforcement action or if they were currently seeking construction
loans. Since the IMP AC program is a pilot study, the State also developed criteria that communities
selected for further assistance must be representative of other communities and that State assistance will
be targeted where it will produce the greatest benefits.
Based on this criteria, the State and EPA are working with four of the approximately 40
communities that returned questionnaires to help them improve the performance and operation of their
POTWs. The State notified these communities with a summary of the data received from the IMP AC
questionnaire as well as a letter informing the community of the problems with their POTW. EID and
EPA personnel met with officials of these four communities, toured the POTWs, and discussed what
assistance the community wanted. State assistance will be customized to the specific set of circumstances
at a POTW. Assistance can vary widely, ranging from additional operator training, to the development of
better diagnostic tests to improve plant operating efficiency, to overseeing equipment replacement or
facility expansion. State assistance could also involve the financial operations of the facility including help
with restructuring user rates, establishing equipment replacement funds, or establishing debt service funds.
For those communities that the State did not identify as having potential compliance problems, the State
sent a summary of the data from the IMP AC questionnaire and a letter confirming their POTWs
satisfactory performance.
COMPLEMENTARY PROGRAMS
The IMP AC program is drawing on a number of other programs important to the goals of IMP AC
that existed prior to the inception of this pilot program. For example, New Mexico offers as well as
coordinates technical assistance for POTW operators. Much of this technical assistance is provided by
New Mexico State University's Utility Operator Training Program which is funded through the University.
The State's Surface Water Quality Bureau's Facility Operations section also provides technical assistance
-------
through funds available from Sections 106 and 104(g) of the Clean Water Act. Communities can contact
either the State or New Mexico State University for assistance or the State may contact a community
directly.
Another program that IMP AC is drawing on is the POTW operator training and certification
program. New Mexico State law requires POTW operators to receive training and pass certification
examinations. The Surface Water Quality Bureau's Municipal Facilities section, In conjunction with the
Utility Operators Association and New Mexico State University's Utility Operator Training Program,
conducts operator training classes. After taking these classes, POTW operators must pass certification
examinations administered by the State.
The State also incorporates water monitoring reports, required under other programs, into the
IMP AC program. The Clean Water Act requires POTW operators to submit discharge monitoring reports
on effluent quality. New Mexico also has a mandatory ground-water pollution discharge program that
State officials see as similar in concept to a MWPP program. Under the ground-water program, the State
requires all dischargers to file routine ground-water quality monitoring reports. The State also issues
ground-water permits that limit effluent discharges. The State uses both the surface water as well as the
ground-water monitoring reports as early warning systems to detect potential problems. EED's District
Offices regularly respond to such problems with on-site visits to discuss possible remedies with dischargers,
including POTW operators. The State has the authority under both the Clean Water Act and its ground-
water program to initiate enforcement actions against dischargers who violate their permit limits.
RESOURCE INFORMATION
Money to finance the New Mexico IMP AC program comes mostly from grants to the State under
the Clean Water ACL Staff time is financed through a few different sources including funds for the
administration of construction grants under Section 20S(g) of the Clean Water Act, funds for surface water
8
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activities under Section 106, and funds from the State revolving fund. The State also provides its own
funds, matching the Section 106 grants.
»
State officials estimated that it would take personnel resources equivalent to approximately 1 full
time employee to plan and administer the IMP AC program for the first year. Planning the program
required the time of five staff members for 13 full days, plus approximately 25 percent of the time of one
other staff person.
The expertise of the staff members required to plan and administer the IMP AC program covered a
variety of disciplines. Personnel included staff members from the enforcement section, the wastewater
treatment operations section, the construction grants section, a sanitary engineer, a technical assistance
specialist from a district office, and a Bureau Chief to coordinate the State's efforts.
The State currently provides these resources by diverting personnel away from their normal
responsibilities. The State is considering, however, hiring a new staff member dedicated solely to IMP AC
if this pilot program is made a permanent program. This IMP AC Coordinator would be responsible for
the day-to-day administration of the program. He or she would coordinate the State's technical assistance
activities for those communities whose POTWs were singled out by the program. The State is also
considering administering the community questionnaire once a year. If that is the case, the IMP AC
Coordinator would also be responsible for disseminating, collecting, and reviewing these questionnaires.
PROGRAM MANAGEMENT
State officials manipulated the data collected from the returned questionnaires by hand to identify
which POTWs needed further assistance. Given the fact that the IMP AC program is a pilot study and that
the data received were relatively limited, State officials saw no need to develop a data base management
-------
system. Officials are still considering whether to develop this program into a permanent program. If they
decide to make IMP AC a permanent program,'officials will reevaluate the need for a data, base
management system at that time.
For more information on New Mexico's IMPAC Program, contact:
Ms. Kathy Sisneros
Chief, Surface Water Quality Bureau
Environmental Improvement Division
State of New Mexico
505427-2792
10
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EXHIBIT 1
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MUNICIPAL WATER POLLUTION PREVENTION PROGRAM
Improving Municipal Performance by Addressing Capacity
NEW MEXICO IMPAC QUESTIONNAIRE
SUBMITTED BY
MUNICIPALITY :
CONTACT PERSON :
MUNICIPAL OFFICIAL
TITLE
TELEPHONE f :
CHIEF OPERATOR :
NAME
TELEPHONE # :
DATE : ..
1989
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New Mexico IMPAC Questionnaire
Improving Municipal Performance by Addressing Capacity
Part 1. INFLUENT LOAOINGS/FLOU
A. List the average monthly volumetric flows and BOOc loadings received at you- fac'l'tv
during the last calendar year. ' ' J
Month
1988 July
August
Stptember
October
November
December
1989 January
February
March
April
May
June
Col. 1
Average Monthly
Influent Flow
(M6D)
Col. 2
Average Monthly
Influent 6005
concentrations
(mg/1)
Col. 3
Estimated Averag-
Influent Loaain
loadings
(pounds per day
** Estimated BOOc loading AVG Monthly Flow (M60) x AV6 Monthly BOOs concentration
(in mg/1) x 8.34.
NOTE: IMPAC Is based on a program developed by tht Wisconsin Department of Natural Resource
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8. List the average design flow and average 8005 loadings for your facility in the Dl
below. If you are not aware of these design quantities, refer to your 04M manual.
Average Design Flow Average Design 8005 Lc
(MGD) (Pounds oer day)
Design Criteria:
901 of the Design Criteria:
C. How many times did the monthly flow (Col. 1) to the WWTP exceed 90t design flow?
(Circle the appropriate number)
0-4 * 0 points; 5 or more « 5 points
D. How many times did the monthly flow (Col. 1) to the WWTP exceed the design flow?
(Ci re Ie the appropriate number)
0 » 0 points; 1-2 5 points; 3-4 - 10 points;
5 or more * 15 points
E. How many times did the monthly BOD5 loading (Col. 3) to the WWTP exceed 901 of the
design loading? (Circle the appropriate number)
0-1 « 0 points; 2-4*5 points; 5 or more » 10 points
F. How many times did the monthly 600$ loading (Col. 3) to the WWTP exceed the design
loading? (Circle the appropriate number)
0 « 0 points; 1 * 10 points; 2 20 points;
3 30 points; 4 40 points; 5 or more 50 points
G. Add together each point value you circled for C through F and place the sum in
the blank below.
C points » ______
0 points _____
E points » __
F points
TOTAL POINT VALUE FOR PART 1
Enter this value on the point calculation tablt on the last page.
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Part 2: EFFLUENT QUALITY/PLANT PERFORMANCE
A. For the permitted parameters, list the average monthly effluent concentration and
loading produced by your facility during the last calendar year. Disregard any column
which are not applicable to your permit. Circle whether you are measuring ammonia
nitrogen (NH3-N) or nitrate nitrogen (N03-N).
(1) Concentration
Month
1988 July
August
September
October
November
December
1989 January
February
March
April
May
June
BOO 5
(rag/1)
TSS
(mg/1)
NH3-N
or N03-N
(mg/1)
Total
Phosphorus
(mg/1)
Fecal
Col i form
(Count/100ml)
PH
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2. Loading
"onth
1988 July
August
September
October
November
December
1989 January
February
Marcn
April
May
June
fibs/day)
TSS NH3-N . . Total Other
or N03-N °hospnorus
(Ibs/day) (Ibs/day) (Ibs/day)
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List the monthly average permit limits for the facility in the blanks below.
Circle whether your permit lists ammonia nitrogen (NH3-N) or nit-ate n't-oqen
Concentration
Fecal
Col i form
(count/100 ml)
Permit Limit:
901 of the Permit
Limit:
BOD5
(mg/1)
TSS
(mg/1)
NH3-N
or N03-N
(mg/1)
Total
Phospnorus Othe
(mg/1) (lis
2. Loading
Penult Limit:
90t of the Permit
Limit:
BOOs
(Ibs/day)
TSS
(Ibs/day)
NHi-N
or N03-N
(Ibs/day)
Total
Phosphorus
(Ibs/day)
Other
(Hst)
C. How many months did the effluent BOOc concentration (mg/1) nr loading (Ibs/day) exce<
90t of permit limits? (Circle tht appropriate numoer)
0.1 0 points; 2-10 points;
5 or more 40 points
3 20 points; 4 30 points
0. HOW many months did tht effluent BOO; concentration (mg/1) or loading (ins/day)
exceed ptrait limits? (Circle tht appropriate number/
0*0 points;
1-2 5 points;
3 or more 30 points
E. How many months did tht effluent TSS concentration (mg/1) or loading (Ibs/day)
exceed 90S of tht permit limits? (Circlt tht appropriate numoer)
0-1 0 points; 2 10 points; 3 20 points;
5 or more * 40 points
4-30 points;
F. How many months did tht effluent TSS concentration (mg/1) or loading (Ibs/day)
exceed permit limits? (Circlt tht appropriatt 'k
0*0 points;
1-2*5 points;
3 or more 30 points
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n
G. HOW many months did the effluent Ammonia-Nitrogen or Nitrate Nitrogen concent-''--"
(mg/1) or loading (Ibs/day) exceed 90% of the permit limits?^ (Circle"'"e
appropriate number)
0-1 » 0 points; 2 10 points; 3 » 20 points; 4 » 30 po:n:s
5 or more * 40 points
H. HOW many months did the effluent Amjnonia-Nltrogen or Nitrate-Nitrogen limit exceed
permit limits? (Circle the appropriate number)
0 0 points; 1-2 * 5 points; 3 or more 30 points
I. HOW many months did the effluent fecal coll form concentration exceed 9OT of the
pe-mit limits? (Clrc)e the appropriate number)
0-1 0 points; 2 a 10 points; 3 » 20 points; 4 = 30 points
5 or more » 40 points
J. HOW many months did the effluent fecal coll form concentration exceed permit
limits? (Circle the appropriate number)
0 0 points; 1-2 » 5 points; 3 or more » 30 points
K. HOW many months did the effluent Phosphorus concentration (mg/1) or loading
(Ibs/day) exceed 90! of the permit limits? (Circle the appropriate number)
0-1 » 0 points; 2-10 points; 3 » 20 points; 4 30 points
5 or more 40 points
L. HOW many months did the effluent Phosphorus concentration (mg/1) or loading (Ibs/day)
exceed permit limits? (Circle the appropriate number)
0 « 0 points; 1-2 5 points; 3 or more 30 points
M. Add each point value circled for C through L and place in the blank below.
C points 6 points _________ K points » ______
0 points H points _______ L points _______
E points . _____ I points ________
F points J points _______
TOTAL POINT VALUE FOR PART 2
Enter this value on the point calculation table on the last page.
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Part 3: AGE OF THE WASTEWATER TREATMENT FACILITIES
A. What year was the wastewater treatment plant constructed or last major expansion to
increase the hydraulic capacity of the plant completed.
1989 (Answer to A.) « Age in years
1989 - - Years
Enter Age in Part C., below.
B. Check the type of treatment facility that is employed:
Factor
Mechanical Treatment Plant 2.0
Aerated Lagoon 1.5
Stabilization Pond 1.0
Other (Specify) 1.0
C. Multiply the factor listed next to the type of the facility your community employs
by the age of your facility to determine the total point value of Part 3:
TOTAL POINT VALUE FOR PART 3 x
(Factor) (Age)
Enter this value or 40, which ever Is less, on the point calculation table on the
last page*
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Part 4: BYPASSING FROM TRIBUTARY SEWERAGE SYSTEM(S)
A. How many times in the last year was there a bypass or overflow of untreated wastewe
either at the treatment plant or within the collection system due to heavy rain o-
snowmelt? (Circle One)
0 « 0 points 1 5 points; 2 » 10 points; 3 » 15 po:nrs;
4 « 30 points 5 or more » 50 ooints
B. Specify now many of the bypasses or overflows were within the collection system or
treatment plant.
Collection System Treatment Plant
C. How many days in the last year was there a bypass or overflow of untreated wastewate
due to equipment failure.either at.th* treatment plant or due to pump problems in :-
collection svstem? _____ (Circle One)
0 points; 1 * 5 points; 2 « 10 points; 3*15 points
A 30 points; 5 or more 50 points
D. Specify how many of the bypasses or overflows were within the collection system or
at the treatment plant.
Collection system Treatment plant
E. Specify whether the bypasses came from the city or village sewer system or from
contract or tributary communities/sanitary districts, etc.
TOTAL POINT VALUE FOR PART 4
Enter this value on the point calculation table on the last pagt.
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