EFFECTIVENESS EVALUATION
OF OPERATOR TRAINING
CONDUCTED UNDER THE
PSC PROGRAM
             >^fcn si?r  A
         Revised March 1973
 U.S. ENVIRONMENTAL PROTECTION AGENCY
        Washington, D.C. 20460

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                 ACKNOWLEDGMENTS

The Environmental Protection  Agency  and Harbridge House
wishes to acknowledge and thank  the  Texas Water Quality
Board's Environmental  Education Program,  the  Texas State
Department of Health's Division of  Sanitary Engineering,  and
the North  Central  Texas Council of Governments  for their
contributions  and  cooperation  in  making  this  publication
possible.

This report addresses  only one of the many training programs
currently underway in the State  of Texas. Recognition should
be given to the cities  of the State for their outstanding record
of training in the field of water quality control. In conducting
and evaluating operator training in the Public Service Careers
Program, it was  determined that Texas,  due to its  comprehen-
sive training efforts, would provide an excellent basis  for con-
ducting this study.

Despite the generous assistance of the organizations mentioned,
the findings,  conclusions and  recommendations presented in
this report remain the  responsibility of Harbridge House.
              For additional copies, contact:
       State & Local Manpower Development Branch
              Manpower Development  Staff
             Environmental Protection Agency
                Washington,  D.  C.  20460

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    EFFECTIVENESS EVALUATION OF
OPERATOR TRAINING CONDUCTED UNDER
           THE PSC PROGRAM
                   by

            J. Craig McLanahan
                   and
              R. Clark Tefft
                 for the
        Public Service Careers Section
  State & Local Manpower Development Branch
        Manpower Development  Staff
       Environmental Protection Agency
               15 June 1972

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                    EPA REVIEW NOTICE
This report  has  been reviewed by the Environmental Protection
Agency and approved for publication. Approval does not signify that
the contents necessarily  reflect the views  and  policies  of the
Environmental Protection Agency, nor does mention of trade names
or commercial products constitute endorsement or recommendation
for use.
                             (ii)

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                          ABSTRACT
The  relationship  between  wastewater  treatment  plant operator
training and  plant  performance in Texas was studied using three
different approaches:

         (i)   An analysis of the performance of a sample of plants
              involved in  Operation  Cleansweep,  a  Texas Water
              Quality Board (WQB) project to clean up the poorest
              performing plants in the state.

         (ii)   A survey of WQB field supervisors and their staffs to
              determine which plants had improved as a result of
              training and why that improvement had taken place.

        (iii)   A statistical correlation of operator  training com-
              pleted and level of plant performance for a sample of
              124 plants.

Plant performance was found to be greatly influenced by training in
all of these  studies,  and this influence was found to be powerful
enough  to  cause some plants to change from a seriously noncom-
pliant status  to  a fully compliant performance — substantially as a
result of training.

Once the magnitude of the performance change was calculated, a
monetary value for the change was estimated using the concept that
the relative cleanliness of the plant effluent was a measure of plant
productivity  which could be  converted into  a "return" on capital
invested in the facility. Accordingly, poor plant performance gave
very low returns, and the improved performance due to operator
training yielded  very high returns estimated at $91  of incremental
asset value  for each dollar invested in training.

Other values  derived in this study include a high investment in plant
per operator, over $64,000,  a figure approximately six times  the
average  industrial investment per production worker.
                              (iii)

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                   TABLE OF CONTENTS

                                                        Page

  I. Conclusions	     1

 II. Recommendations   	     3

III. Introduction	     5

    A.  Purpose and Scope	     5

    B.  Research Methodology	     6

IV. The Impact of Operator Training on
    Wastewater Treatment Plant Performance	    11
                                                   : i
    A.  The Impact of Training in Improving
         Wastewater Treatment Plant Performance	    11

    B.  The Impact of Training in Sustaining
         High Wastewater Treatment Plant
         Performance	    32

    C.  Conclusions Regarding the Impact of
         Operator Training on Plant Performance	    46

 V. The Return on the Public Investment in
    Wastewater Treatment Plant Operator
    Training	    51

    A.  Value of Capital Assets per Operator	    51

    B.  Wasted Investment Through Substandard
         Effluent	    58

    C.  Conclusions Regarding the Return on the
         Public Investment in Wastewater Treat-
         ment Plant Operator Training   	    64

APPENDIX A    ECI per Operator Calculations
                for 19  Case Studies  	    65

ACKNOWLEDGMENTS  	    67
                             (iv)

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                     LIST OF EXHIBITS
                                                         Page
Exhibit  1     Summary of Operation Cleansweep
              Case Analysis	    17

Exhibit  2     Summary of WQB Supervisor Survey
              Case Analysis	    29

Exhibit  3     Typical Plant Entry in WQB Self-
              Monitoring Computer Reports  	    33

Exhibit  4*    Operator Certification Requirements
              in Texas	    35

Exhibit  5     Sample Computerized Correlation
              Matrix   	    38

Exhibit  6     INT:PER Correlations   	    39

Exhibit  7     TA:PER Correlations   	    40

Exhibit  8     TfliPER Correlations   	    43

Exhibit  9     TcPER Correlations	    44

Exhibit 10     Relative Correlation Frequencies of
              TA> TB, and TC Factors with
              Performance	    45

Exhibit 11     Correlation of Changes in Plant
              Performance with Training and
              Staffing Parameters	    47

Exhibit 12     Relative Values of Correlations of
              Changes in Plant Performance with
              Training and Staffing Parameters  	    48

Exhibit 13     Calculated Capital Investment per
              Operator for 50 Randomly
              Selected Plants	    53

Exhibit 14     Summary of Black and Veatch
              Plant Type Categories   	    55
                              (v)

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                                                          Page

Exhibit 15     Per Capita Wastewater Treatment
              Plant Investment Cost Data	    57

Exhibit 16     Calculation of "Stop-Loss" on
              Capital Investment and Return on
              Training Investment in 19 Case
              Studies	    60
                             (vi)

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                         PARTI
                     CONCLUSIONS
 Three  independent investigatory  tracks have  produced  com-
 plementary results which, when taken together, prove beyond
 reasonable doubt that the Public Service Careers Program type
 of training of municipal wastewater treatment plant operators
 improves  skills and increases plant effectiveness.  However, in
 specific cases  the  use  of  trained  operators alone may  be
 ineffective in promoting good plant performance.  The  avail-
 ability of adequately  trained personnel alone does not ensure
 effective operation;  however,  their unavailability ensures  in-
 effective operation.

 Use of untrained or inadequately trained operators exposes the
 public to a loss of the  benefits from a productive public asset, in
 effect  decreasing the return on  capital invested in treatment
 plants.  While  this loss is  difficult  or impossible to  assess
 precisely, certain useful, if imperfect, estimates have been made.

 (i)   Risk of capital  dissipation is substantial if untrained or
      inadequately trained operators are utilized. Based on Texas
      data,  a  conservative  estimate  of average  plant  value
      entrusted  to each operator is  approximately $64,000.
      Because of understaffing, individual operators are actually
      entrusted with capital plant of up to $160,000.

(ii)   In 19 Texas plants where training during 1971 has been
      identified as the  substantial cause  of improved  plant
      performance, it  is estimated that  almost $5  million in
      capital dissipation has been avoided through training. The
      cost  of  training in all of  these  plants, at  maximum
      estimate,  was $62,715.  The estimated return on  each
      dollar invested  in  training  in  these  plants  in terms of
      capital stop-loss is $91.

(iii)   Other substantial but unmeasurable returns from training
      in many  of the other  1,000  or so  Texas plants  have
      undoubtedly occurred. Returns from these plants plus the
      19 above may be contrasted with the $690,000 in federal
      investment in operator training in Texas between January
      1969 and December 1971.

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    (iv)  In 19 Texas plants, BOD/TSS performance has improved
         in a range of 112  percent to 334 percent as substantial
         result of the operator training.

•    Training probably increases the cost of operations and routine
     maintenance which are funded out of local funds. Therefore, by
     itself,  training may not be  an appealing investment  to local
     decision-makers.  However, in Texas, and in other states which
     provide heavy fines for noncompliant plant operation, training
     which moves a plant to compliance will provide a substantial
     stop-loss return to a locality.

•    Prior to the  conduct of this study, the Harbridge House project
     team had anticipated that operator training did  have a positive
     effect on plant performance. However, the measurable value of
     such training in  terms  of the return  on investment in that
     training astounded us.

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                            PART II
                     RECOMMENDATIONS
This  study shows the  salutary  effect  of operator  training on
treatment plant effectiveness in Texas. Further,  with regard to  a
sample of 19 established Texas plants, it indicates an extremely high
return on  training investment  in  terms of halting  dissipation of
capital invested in plant and in other unmeasured ways. It also shows
a high plant investment per operator and thus displays the substantial
risk in entrusting plant to untrained or unlicensed operators. We see
no reason why the Texas findings for established plants are not valid
for the rest of the United States; the extent of the return on the
training dollar may vary, but even a substantially smaller return than
shown in Texas remains a very excellent investment.  Therefore, we
recommend that EPA proceed as rapidly as possible to develop and
implement  programs designed to ensure training and certification for
plant operators.

Anticipated federal and state capital investment in new plants during
the next five years is in  the billions.  We can speculate that the
relationship of trained operators to plant effectiveness for new plants
coming on  line  will be similar to that for established plants as
determined  in this study.  However, this is speculation. We recom-
mend that further research and analyses be undertaken to establish
the effect of operator training on new  plant effectiveness  and the
return on investment in training operators for these plants.

In anticipation of a finding from  such research and analyses that
operator training  does  have  the result of preventing  substantial
capital dissipation in new plants, we recommend that EPA take the
necessary legal and administrative steps necessary to be immediately
ready to make operator training and  certification a condition of
plant construction grants. Rapid implementation  action would be
prudent in order to prevent wasting of federal capital investment.

EPA should note that a requirement for training will create a demand
for training. The  EPA current estimate for additional operators  is
43,600 in the next five years. (This is in  addition to upgrade training
demands for  existing  operators necessary to protect the present
investment in plant.) This additional demand to man the new plants
underscores our previous recommendation that EPA press  forward
with  programs designed to ensure training  and  certification for
operators.

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The  report notes that available evidence suggests that routine plant
operation and  maintenance  costs  increase with the use of trained
operators. Since  these  costs  are born by the localities which are
generally financially hard pressed,  there is likely a disincentive for
localities to encourage operator training.  Some states, such as Texas,
have  a procedure  for  fining  localities with plants  not meeting
specified performance requirements. Such a fine system provides an
incentive for localities to see to operator training. We recommend
that EPA encourage the states to adopt and/or enforce a fine system
or some other mechanism which provides an incentive to localities to
train and certify all operators.

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                           PART m
                       INTRODUCTION
A.   Purpose and Scope

This report  presents  the results of  a study conducted for  the
Environmental Protection Agency (EPA) regarding the effectiveness
and  return on  investment of wastewater treatment plant operator
training — particularly that supported by  federal funds through the
Public  Service Careers (PSC) and  similar  programs. Because  of the
similarity of operator training conducted under the sponsorship or
influence of EPA in terms of work skills  developed and substantive
content, PSC program results can reasonably be imputed to other
programs, and vice versa.

The  effectiveness of wastewater treatment plant operator training
programs in increasing the applied skills of their graduates — the first
major area of investigation — can most appropriately be measured in
terms of quality of plant output or effluent. This study examines the
impact of training on plant performance in two ways: (i) the ability
of training to improve plant performance by changing operator skills
and  behavior,  and  (ii)  the influence  of training in  maintaining
consistently high performance  at  already  successful wastewater
treatment plants.

On the basis of the conclusions drawn from this first  analysis, the
study proceeds to examine the  return  on the public investment in
operator training. Although it is possible to total the monies spent on
training, it is probably impossible to determine the definitive dollar
return  from operator training, and certainly it was impossible to do
so within the resource limitations of this study. However, the public,
through federal and state agencies, has made a substantial  capital
investment in the construction of wastewater treatment plants,  and
training  may be viewed as an expenditure to ensure the  proper
utilization of these plants. These monies have been invested with the
expectation that specified quantities of wastewater will be treated to
specified levels of cleanliness. In this second investigation, training
was  therefore viewed in terms of its ability to prevent or substan-
tially  reduce  faulty operations  that  might  dissipate the  public
investment through delivery of an effluent of substandard quality or
impairment of plant  capability or productivity.

The  conclusions and recommendations   derived from these two
investigations have been  presented in Parts I and II, respectively, of
this  report. Section B of this  part describes the  various research

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activities that were conducted in support of these investigations. The
results of the research and analysis are presented in detail in the
remainder of this report, as follows:

         •    Part  IV: The Impact of Operator Training on Waste-
              water Treatment Plant Performance

         •    Part  V:  The  Return on the Public Investment  in
              Wastewater Treatment Plant Operator Training

8.   Research Methodology

Because a study of this nature required uniformity and compatibility
of data, and because the scope  of the study was necessarily limited,
all of the work was performed  within one state. The state  of Texas
was  selected because  it contains a  particularly  large number  of
treatment plants, has received considerable federal operator training
funds, and is very advanced in its policies and procedures relating to
water pollution control.

     1.   The Impact  of Operator Training on Wastewater Treat-
          ment Plant Performance

The  initial hypothesis for this portion of  the study was that the
relative effectiveness of training could be determined by an  examina-
tion of "paired" plants that were similar in  all design characteristics
except that one of them was staffed by trained operators and the
other staffed by  untrained  personnel. Upon initial investigation  in
Texas, this approach was rejected since it was impossible to establish
pairs in which the training factor was the only independent variable
affecting  effluent quality.  Other variables that precluded pairing
included plant  capacity,  load, type of treatment, age  and condition
of the  plant,  and level  of  staffing  (in  comparison to  design
standards) — each of which  tended to combine with the others in a
unique way  for  each plant. Therefore, the approaches described
below were developed and implemented.

          a.   The  Effectiveness of Training in Improving Perfor-
mance. Examination of the impact of training in improving perfor-
mance was complicated by the lack of consistent data as the basis for
a statistical sampling of  plants across  the state of Texas. No single
source of information exists that presents training completed or level
of operator certification achieved together  with plant performance
within Texas. Existing sources of information available from separate
state agencies (described below) present  time-series data  for plant
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performance and cross-sectional data on operator certification and
training as of the end of 1971. These data had to be manually looked
up and cross-filed to get complete data on each plant to be studied.

Therefore, a survey of the results of operator training in all of the
municipal treatment plants  in Texas  would have been impossible
within  the  resources  available  for this  study. Accordingly, an
approach was sought to identify specific plants where training might
well have had a specific effect and then to determine the details of
that effect  by "before" and "after" training analyses. The specific
approach initiated was two pronged.

              (1)  "Operation Cleansweep" Analysis. First, 1971
and  1972 performance was analyzed for 16 plants whose perfor-
mance had been so poor during the first quarter of 1971 that they
had been summoned by the Texas  Water Quality Board's (WQB's)
"Operation Cleansweep" project  to explain the reasons  for their
substandard performance  and to  devise possible  solutions. The
theory of this examination was that operator training might well
have been instituted as a performance remedy in these plants.

              (2)  WQB  District Supervisors Survey. To supple-
ment this  analysis,  the 12 district Texas  WQB supervisors were
surveyed to obtain professional opinions as to which  plants had
benefited from operator training since 1970. Although the resulting
sample of 51  plants does  not  necessarily include every plant in the
state that benefited from training during the specified period and was
not selected according  to random statistical methods, it does permit
an  assessment  of the  types of plant performance and  operator
behavior improvements that may be realized through training.

         b.   The Impact  of Operator  Training  in Maintaining
Consistently  High  Performance.  The  effectiveness of  training  in
maintaining consistently high performance was approached through
computer analyses  of  relevant data on performance, certification,
and training available through Texas  state agencies.

Computerized data from  the  WQB's self-monitoring reports main-
tained on  a monthly basis yielded plant performance data with
respect to WQB-determined levels of capacity and treatment effec-
tiveness. Training Jevels were derived from computerized information
maintained by the Texas Department of Health which gave the name
and certification level  of each certified wastewater treatment plant
operator,  arrayed   by  town  and  certification  level.   Because
maintenance  of  certification is  contingent  upon completion of a

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quota of training hours within a time period, certification was used
as a surrogate for or indicator of the existence of training in this
analysis.

Plants were selected from the WQB printout for which at least six
months of performance data were available and which ranged in size
between  one and twenty million gallons per day (MGD) in design
capacity. Then the number of certified operators at each level in the
town in which each plant is located were counted and merged with
the plant data to form a composite computerized data source relating
plant performance  data  to operator  certification  levels.  For the
purposes of this study, it was necessary to assume that each operator
listed was employed by the wastewater treatment plant in the town
where he worked.

     2.    The Return on  the  Public  Investment  in Wastewater
          Treatment Plant Operator Training

An attempt was made to develop some quantitative insights into the
dollar  value of the benefits  that  can be  derived  from operator
training.  The scope of this study precluded estimation of the precise
dollar value of such benefits. However, it was considered possible to
develop numbers that would be useful to decision-makers considering
the desirability of sponsoring and/or conducting additional operator
training.

The value of training benefits was viewed  from two points of view.
First, the value of the capital assets entrusted to the care of
individual operators in Texas was  estimated on the basis of data
obtained through the EPA  STORET information  system, the Texas
Water  Quality  Board, and  current literature.  Second,  the capital
investment that is wasted when a treatment plant does not fulfill its
BOD and TSS removal specifications was  estimated on the basis of
Texas WQB performance  data on plants known to have experienced
performance improvements following operator training.

Both of these approaches emphasize the value of operator training by
comparing the relative value of training benefits to the estimated cost
of training individual operators.  In effect, training cost is-viewed as
the cost of insuring that capital investment will be used properly and
effectively to produce the intended returns in  terms of effluent
quality.

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     3.    Validity of Study Conclusions

This report is a first in its attempt to make a quantitative assessment
of the effectiveness of wastewater treatment operator training and to
determine  the cost  effectiveness  of such training.  Despite  the
limitations of the research data base, the conclusions appear very
strong that training can have a key role in improving performance if
properly utilized and in maintaining consistently high performance
where good  performance has been  previously established.  In addi-
tion,  regardless of the measure of value that is used,  the economic
return from training in relation to its cost is enormous. It is expected
that a broader scale  investigation either within the state of Texas or
throughout the country would only add further evidence in support
of these conclusions.

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                          PART IV
           THE IMPACT OF OPERATOR TRAINING
   ON WASTEWATER TREATMENT PLANT PERFORMANCE
The response of an operator to formal training and the response of
plant performance to a newly trained or updated operator tend to be
unique to each combination of operator and plant. In this respect, it
is difficult to develop a formula which will express across the board
the impact that operator training  may be expected to have on plant
performance. Therefore, in this report, training was viewed from two
perspectives:

         •   Ability to improve faulty performance.

         •   Ability to sustain high levels of performance.

In some  cases, training  can be  identified  as  the only  factor
influencing performance, while in others it acts in combination with
other stimuli (such as WQB pressure or new plant construction).

A.  The Impact of Training in  Improving Wastewater Treatment
    Plant Performance

In an effort to gain an impression of the impact training might have
on performance,  an  examination  of the Water  Quality Board's
"Operation Cleansweep" and a survey of 12 WQB district supervisors
were conducted.

    1.   Operation Cleansweep

         a.   Overview.  Operation  Cleansweep  is the WQB's on-
going  project to upgrade the performance of Texas  plants not
complying with Texas' standards of operation. The Board holds
monthly hearings on water quality problems and in the first three
months of 1971 brought 16 plants to testify as to the nature of their
performance  problems and  any  corrective  action that  was either
planned or under way. These 16 plants all were drawn from five of
the 12  WQB districts in Texas; these  five districts have a total
population of approximately 720 discharging plants, as revealed on
the self-monitoring reports filed monthly with the WQB.
                t.
We have traced the histories of these plants subsequent to the
hearings to  determine to  what extent training  may have had an
influence  in  performance  improvement, where such improvement
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occurred, and to estimate the nature of the training benefits. The
problems which brought the plants there and the suggested remedial
actions  were  identified  from  the  minutes of the hearings; the
subsequent history of each of  the plants has been gained through
interviews with the surveillance staff in charge of these investigations
and the performance monitoring system of the Water Quality Board.

The   16 case  histories  developed  during  this investigation are
presented in  subsection b, and the findings that emerged from the
Operation Cleansweep study are summarized in subsection c.

         b.   Operation Cleansweep Case Histories

    •   Case 1

Town 1 had two  severely  overloaded plants and  was summoned
before the WQB  twice in the first quarter of 1971. One part-time
uncertified  operator  was  in  charge  of  both  plants under the
supervision of a licensed municipal utilities director. Just prior to the
hearing,  a  WQB  inspector had found  in both plants poor effluent
quality,  poor  maintenance and  operating  practices, mechanical
reliability  problems,  high  infiltration  of the  collection  system
unnecessarily loading the plant, a high frequency of bypassing and
sewer overflows,  and a failure to submit self-monitoring reports and
to report overflow incidents as required.

At the time of the hearing, the town officials agreed to explore the
possibility of joining a large river basin authority as a means of taking
some of the load off its two small plants.

Since the  hearing this town has become self reporting and has
managed to get the river basin authority to take a small part of the
load from one plant and consider its application for membership, but
the two small plants are still overloaded. There was some improve-
ment in effluent  quality in the balance of 1971,  largely as a result of
the prodding and close supervision of WQB officers, but performance
was still below specification. Training has not been a factor in this
situation to date.

    •   Case 2

The plant in  Town 2 also lacked a certified operator and had a high
rate of infiltration and mechanical reliability problems when called
before the Board. Subsequently,  the hiring of two properly trained
and licensed  operators, the installation of lab equipment, and the
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enforcement of the town's industrial waste ordinance (resulting in
the  closing  of the  major  offending industrial  facility) have  all
contributed to dramatic improvement in the plant's performance in
1971. The plant is now compliant with WQB specifications. There is
no way to distinguish  the influence of training from that of better
enforcement of the waste ordinance in this case, but WQB officials
have commented that  without the trained personnel in place, the
necessary lab work and enforcement activities could not have  been
carried out.

     •     Case 3

This city's small plant was severely overloaded, and the results of the
WQB hearing indicated that the plant should both  augment and
upgrade its facility. The town has not voted the necessary financing
for these changes, but the operators at the plant have managed some
improvement in effluent quality. The potential for training  impact
after addition of new facilities is strong.

     •     Case 4

This plant was determined to have poor quality effluent and needed
to augment its facilities to remedy an overloaded condition. Despite
this problem, censure by the  WQB, and a change in management, in
early 1971 a bond issue for construction failed to pass. During the
rest of 1971, the plant managed to maintain an essentially constant
biological oxygen demand (BOD) and total suspended solids (TSS)
output  despite increasing overloading.  The potential for training
impact after addition of new facilities is strong.

    •     Case 5

This small plant was consistently operating in noncompliance with its
permitted BOD and TSS levels. After being called before the WQB, it
hired a consulting engineering firm in April, and in October dramatic
performance  improvement brought both BOD and TSS performance
to compliance levels. Training did not appear to affect this situation
directly.

    •     Case 6

In the hearing before  the Water Quality  Board, this plant's poor
performance  was attributed to defective mechanical procedures and
faulty or inadequate equipment. Following the WQB citation, a new
board of directors was appointed that committed itself to resolving
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 the plant's performance problems.  Subsequently the mechanical
 operations improved,  with an attendant improvement in effluent
 quality, and the board of directors applied for a construction grant
 to enlarge the facility. Although training was not applied directly in
 the resolution of this plant's problems, the deficiencies noted by the
 WQB   in  its  citation — requiring  improvements  in  mechanical
 processes and equipment — are the types of improvements that might
' have been initiated automatically by a properly trained operator. The
 potential for training impact after addition of new facilities is strong.

     •    Case 7

 This plant was not chlorinating its effluent sufficiently, but in other
 respects its performance was satisfactory on BOD and slightly high
 on TSS. An increase in chlorination in April 1971 cured the problem.
 Performance on both BOD and TSS improved steadily through 1971,
 largely as a result  of operator  training, particularly  for the lead
 operator in this plant.

     •    CaseS

 Like Case 7, this plant was not sufficiently chlorinating its effluent.
 At the end of August 1971, however, heavier chlorination began, and
 that problem has been resolved. BOD performance was not a serious
 problem  at this plant, but  suspended solids performance was
 noncompliant. During the year, operators of this large plant received
 increased training and managed  a noticeable improvement in TSS
 measures, although they  are not yet in compliance; some plant
 renovations are required before full compliance can be achieved.

     •    Case 9

 This plant was not overloaded in  1971  (except for a one-month
 seasonal peak), and its performance is well within the compliance
 range. However, it was brought before the Board because of a serious
 and worsening problem with suspended solids removal. Because the
 problem is caused by industrial waste, the city has been told to pass
 and enforce an industrial waste ordinance. It is expected that this
 measure will cure the problem and that training is not a factor in this
 case.

     •    Case 10

 This plant was and still remains seriously noncompliant on BOD and
 TSS, and it began self-reporting only late in 1971. At the time that
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                  EXHIBIT I
SUMMARY OF OPERATION CLEANSWEEP CASE ANALYSIS
Case
1
T
3
4
5
6
7
8
9
10
11
12
13
14
15
16
Problem
Overloading, others
Poor operation
Overloading
Overloading
Poor operation
Inadequate equipment
Low chlorine, non-
compliant TSS
Low chlorine, non-
compliant TSS
Heavy industrial
waste load
Poor operation
Poor operation
Deteriorated plant
Overloading
Overloading,
infiltration
Poor operation
Poor operation
Solution Selection
Offload
Hiring of trained
operators
Augment facilities
Augment facilities
Consulting engr.
Augment facilities
Chlorination and
training
Chlorination and
training
Industrial waste
ordinance
Training
Hiring of trained
operators
New plant
Regional affiliation
Consulting engr.
None taken
Chlorination
Apparent Influence
of Training
None
Strong
None
None
None
None
Moderate
Moderate
None
None
Strong
None
None
None
None
None
Potential Influence
of Training
None
N/A
Strong
Strong
None
Strong
N/A
N/A
None
Strong
N/A
Strong
None
None
Strong
None
                     17

-------
supervisors of the WQB. These men have surveillance responsibility
for monitoring plant performance and supervising or enforcing the
solution of individual pollution control problems. Typically they are
professional engineers and have engineers, former senior wastewater
treatment plant operators, and biological scientists on their staffs.
They report to one statewide authority, but they and their staffs
have a close and professional view of plant  operations at the local
level.

The initial contact for this survey was  made by memo from WQB
headquarters, followed  by a  telephone contact seeking  specific
information on  a  case-by-case basis. Generally the WQB supervisors
gave us their impressions of plants which had benefited from  training
without referring to specific data on personnel in their districts who
had been recently trained. Some supervisors from the larger districts
assembled  notes summarizing the collective impressions of their
subordinates; others provided direct answers based upon  their own
knowledge,  and still others, while voicing strong support for  training
as beneficial in  many ways, did not describe specific case examples
from their districts. Where the number of cases described appeared to
be large and the supervisor wished to submit a return memo in lieu of
a telephone contact, this was accepted. In addition, actual visits were
made to two district supervisors with particularly interesting or long
answers.

The cases emerging from this survey reveal both the unique situations
and the common patterns which exist in plant response to training.
Each case is described in subsection b, and a summary analysis and
relevant conclusions are presented in subsection c.

         b.   Cases of  Training Benefits Cited by  WQB  District
              Supervisors
Plant 1 is a new plant which was off to a bad start with an operator
who did  not understand how to run it. Following training, however,
and  some assistance from a  consulting engineer,  the operator's
attitude and interest dramatically improved. Since the plant was new,
effluent quality had not been low but would have degraded over time
if the initial operator  attitudes and  knowledge had  not been
improved.
                               18

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     •    Case 2

The performance of this plant was dramatically improved as a result
of  a combination  of operator training  and  support from  water
quality inspectors who have assisted the town in gaining control over
the  industrial waste from a food processing plant.  As a result of
training,  the operator was sensitized to the problem and was able to
work with the surveillance agency to collect the data necessary to
effectively enforce its industrial wastewater ordinance.

     ป    Case 3

As a result of training, the operator of this older plant has given it a
face-lifting and now practices greatly improved maintenance pro-
cedures.  Unfortunately, because of the plant's age, its performance
has not been improved.

     •    Case 4

As  a result of his training, the operator  in Case 4 realized that his
plant was not physically capable of making its target. Nevertheless, in
order to  get the  best possible performance out of his facility, the
operator   overhauled the plant  and  has managed  to arrest  the
performance degradation that had been taking place.  In addition, in
order to  avoid loading up the receiving waters with inordinately high
BOD and TSS loads, he has developed a revenue-producing irrigation
use for part of the plant effluent.  Realizing also that a new plant was
the only  long-term satisfactory solution, this operator has spoken at
meetings and has taken other actions to help the town to get a bond
issue passed for a  new plant.

     •     Case 5

As  a result of training, this operator's attitude and "housekeeping"
practices have greatly improved. Because  the plant is a no-discharge
plant — that is, the effluent,  if any, does  not enter public waters —
the performance could not be assessed.

     •     Case 6

Operating difficultie's and neighborhood  complaints of foul  odors
have been eliminated by the operator in Case 6 since he completed
training.  Prior to the  training, the  operator  was shutting  down
aeration  blowers  at night   to  save  money — thus  rendering  the
treatment process anaerobic.  Blowers now run full time. Actual plant
                               19

-------
performance could not be assessed because the plant is a no-discharge
installation.

    •   Case 7

Following training, this operator has acquired a new laboratory for
his plant, beautified its grounds, become concerned over compliancy,
and  joined the  required  statewide self-monitoring  program,  in
addition to improving effluent quality. Prior to training, the plant
operator had not been  submitting reports and, in fact, had been
discharging effluent into the wrong stream (of two that ran close to
the grounds), in violation of the plant's waste control order (WCO).

    •   Case 8

As a  result of training, the  operator in this plant set  up his own
laboratory. The training has created more interest in and understand-
ing of plant operations. Although  the flow figures indicate that the
plant  is operating at  or  slightly above its WCO specification, BOD
performance has  dramatically improved (although somewhat at the
expense of TSS performance).

    •   Case 9

Training has given this plant a certified  operator  and  has enabled
him,  with  the support  of  some plant redesign, to greatly improve
BOD  and TSS performance. Although the redesign  of the plant was
accomplished professionally,  the  operator himself supervised  the
rebuilding operations.

    •   Case 10

Training provided this plant  with  a certified operator who set up a
new lab for his plant. Due to the seasonal loads  on this plant and
occasional failures to  report performance, it is not possible to detect
a change in performance.

    •   Case 11

This municipality has instituted a policy of having all of its operators
trained to at least the lowest certification level. As a result of the
new policy and the resultant efforts to train  all  operators,  strong
improvement in BOD performance has been noted and the plant is
now fully compliant on both BOD and TSS.
                               20

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     •    Case 12

Training provided this  plant  with a certified operator who has
improved both BOD performance and plant appearance. He has also
assumed the responsibility for his own lab work.

     •    Case 13

Training provided for the certification of an operator at this plant.
With his new knowledge, the operator has been able to dramatically
improve his BOD performance and make some improvement in his
TSS performance.

     •    Case 14

Since this operator returned from training, he has exhibited greater
enthusiasm for his job and plant  performance has improved on both
BOD and TSS.

     •    Case 15

This plant  has  a laboratory which was unused prior to operator's
attending  a training  program. Following the program, he  is now
performing  his own lab work.  Although  plant performance was
satisfactory  at the outset, further improvement in plant performance
has been noted.

    •    Case 16

Training has helped  the supervisor of  this plant move up to a B
certificate and has influenced him to plan for the establishment of a
plant laboratory. Although TSS  performance has  continually been
satisfactory, BOD levels are now  compliant, and performance on
both measures has been improving steadily  since the completion of
training,

    •    Case 17

The operator of this plant has made a notable improvement in his
knowledge  as well as in  plant performance.  BOD levels, which were
originally satisfactory, are now well within required levels, and TSS
has been brought from a substandard level  to  well within the
compliance range.
                              21

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     •    Case 18

Training upgraded the license of one operator at this plant, as well as
providing  him  with an  opportunity to improve his reading  and
writing  abilities, which were originally marginal.  In addition, plant
maintenance has been improved.  Performance change could not be
assessed because the plant is a no-discharge facility.

     •    Case 19

Training provided  this plant with  one upgraded operator and six
newly  certified  operators. Although plant performance  has been
consistently compliant, the training has given the operators the skills
to improve maintenance.

     •    Case 20

Training programs have  allowed  seven operators to  upgrade their
licenses and two more to become certified. Although the supervisor
of the plant claims to see no performance improvement, the WQB
self-monitoring report shows an  improving  but  still-noncompliant
effluent.

     •    Case 21

Through training, this large plant managed to upgrade 19 operators
in pay and status. Unfortunately, because the plant is a no-discharge
installation, differences in performance could not be  observed, but
better  housekeeping and maintenance around the plant have been
noted.

     •    Case 22

The  plant also upgraded its  operator  through training, and an
improvement in maintenance and housekeeping  has  been noticed.
Performance improvement could  not be assessed, however, because
this plant is a no-discharge facility.

     •    Case 23

Maintenance and housekeeping at this no-discharge plant improved as
a result of training. No performance change could be measured.
                              22

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    •    Case 24

This plant has a certified C operator who takes every chance to go to
the courses offered, attend meetings of local operators, and assist
neighboring operators,  despite the fact that he has town duties in
addition to wastewater treatment plant operation. The performance
of this plant is remarkable in the low BOD levels it has achieved, and
the operator managed a significant improvement in TSS performance
during 1971.

    •    Case 25

By hiring  two trained and licensed  operators  and enforcing its
industrial  wastewater ordinance,  this  plant managed  a  sufficient
improvement in both BOD and TSS performance to progress from
noncompliant  to  compliant  status. (This case is a sample plant as
Case 2 of the Operation Cleansweep Survey.)

    •    Case 26

Through training, the operator of this plant gained certification. This
man achieved  compliant operations early in  1971 and continued to
improve BOD performance throughout the year.

    •    Case 27

This town abandoned its old plant and hired a new full-time certified
operator  to replace the three garbage collectors who had been
tending the old plant  on a part-time basis. The new  trained and
certified  operator  has been  able to improve his performance
consistently, bringing  BOD   and TSS  effluent  levels  down to
exceedingly low levels.

    •    Case 28

In the  two years before being called before the Water Quality Board,
this plant had not had a certified operator and had been experiencing
BOD levels  in excess of 170, with TSS at 66 in early 1969. At this
time, sludge banks were observed regularly in the stream into which
the plant effluent was discharged. The hiring of a different but still
unlicensed  operator in  1970  improved operations somewhat,  but
performance  still  fluctuated  and   sludge  beds   were   cleaned
inconsistently.
The present operator was unlicensed when hired but had a letter in
training — the  equivalent  of  a  license  prior  to completion of
                              23

-------
sufficient experience to qualify for certification. Following several
months of work, he attended a technical operations and maintenance
training school for six weeks. Following training, plant  operations
improved from noncompliant to well within compliance levels on
BOD, although TSS is still noncompliant.

     •   Case 29

Through  training of its operators,  this plant, although overloaded,
has managed to achieve compliant BOD and TSS performance most
of the time. It does, however, have  some equipment design problems
which cause excessive bypassing to occur.

     •   Case 30

As  a result of training, this operator  converted his plant from a
discharging to  a no-discharge installation by adding  a pond to catch
the effluent - thereby avoiding discharging the effluent into public
waters.

     •   Case 31

Training  of one of the two operators in this facility has improved
BOD performance from noncompliant  to  compliant. TSS perfor-
mance has  no compliance specification and does not appear to have
changed in the period during which BOD performance has improved.

     •   Case 32

This  older plant achieved compliant performance as a result of
operator  training (although the operator has not yet qualified for
certification). Following his training, the operator greatly improved
BOD performance, which had been noncompliant. He  also tfiade
some improvements in TSS, which had already been satisfactory as a
result of  a generous limit in the plant's permit. A big improvement in
housekeeping has been noticed.

     •   Case 33

An  older licensed operator in this plant was replaced by a newly
trained and licensed  man who cleaned up the plant and  equipment
thoroughly and improved  BOD performance from noncompliant to
compliant. Data on TSS performance were not available.
                              24

-------
    •    Case 34

As a result  of training, this plant's operators — previously uncerti-
fied — are now licensed. Plant performance has steadily improved on
BOD to within compliance levels and remained steady on TSS, which
is still slightly substandard.

    •    Case 35

As  a  result  of training, the  operator  of this plant  received
certification and demonstrated an improved attitude and motivation
toward  his  work.  Following  training, he  improved the appearance
and  general maintenance  of the plant. Because the plant is a
no-discharge facility, specific performance figures  are not available.

    •    Case 36

In this large plant, previously uncertified operators gained certifica-
tion, and certified operators upgraded their  licenses as a result of
training. Improved general maintenance has been observed, and the
plant's  performance  on both  BOD  and TSS  has  changed from
noncompliant to well within compliance limits.

    •    Case 37

Training in this case enabled an operator to gain certification, and he
has exhibited increased  interest and motivation.  No performance
information  on this  plant was available because  it  is  not  self
reporting.

    •    Case 38

The acquisition of certification by the operator of this plant after
training has led him to show improved motivation and interest in his
work. Since completing training, he has improved or renovated parts
of the plant, and BOD  (already compliant)  and TSS performance
appear to have improved somewhat,  although the WQB has not yet
specified a TSS compliance standard for the plant.

    •    Case 39
                  M.

This plant's operator  achieved certification and  exhibited improved
motivation after receiving training. He improved general maintenance
around  the  plant and has brought BOD  performance into compli-
ance. TSS performance has improved but still  remains noncompliant.
                               25

-------
     •    Case 40

This plant's operator, as a result of training, upgraded his license and
has  been exhibiting  stronger motivation and higher morale. In
addition, the plant performance has improved on both BOD and
TSS, although the plant is still noncompliant on both measures.

     •    Case 41

This plant has had its operator certified through training. In addition
to showing increased motivation, he has improved maintenance and
has raised  BOD performance from noncompliant  to compliant —
somewhat at the expense of TSS performance (for which WQB had
not specified a target).

     •    Case 42

At  this plant, new operators gained certification and at  least one
operator upgraded his license. Both motivation and BOD perfor-
mance have improved, although BOD  performance was originally
compliant. TSS performance is somewhat noncompliant  and has
remained virtually unchanged.

     •    Case 43

The operator of this no-discharge plant received  a new  operator
certification and displayed  improved attitude and morale following
training. Performance improvement could not be determined, be-
cause of the no-discharge nature of the plant.

     •    Case 44

Training provided  both new and upgraded operator certificates for
the operators at this plant.  Aided by new treatment facilities, these
operators have maintained  consistently a very high quality effluent
on both BOD and TSS.

     •    Case 45

Training allowed the operator of this plant to upgrade his certificate.
As a result, he displayed notably higher morale and motivation and
made  improvements  in  plant  maintenance.  He  improved  BOD
performance from noncompliant to compliant; TSS performance had
no specification but appeared to be getting slightly worse.
                              26

-------
    •    Case 46

An upgraded operator certificate and improved maintenance and
attitude were the benefits of training for this plant. Effluent quality
had been satisfactory and remained consistently good.

    •    Case 47

Upgrading of an operator certificate and the certification of a new
operator were achieved as a result of training. Attitudes improved
and BOD performance, which  had  been somewhat erratic, settled
down to a position well  within the compliance range.  TSS perfor-
mance has remained compliant.

    •    Case 48

Following training, this plant's operator became newly certified and
exhibited an improved attitude  toward his work. He renovated parts
of the plant and generally improved maintenance. Erratic BOD and
noncompliant TSS performance settled down to values well within
compliance ranges.

    •    Case 49

This  plant's  operators  became newly  certified  and motivation
improved as a result of training. Maintenance procedures improved,
and plant renovation was undertaken.  BOD performance, which was
borderline  compliant,   improved   to  well  within  compliance
tolerances. TSS performance was not specified in the permit and did
not change significantly.

    •    Case 50

The operator of this plant — who had already been effective prior to
his recent training — has begun to do his own lab work. Performance
figures show some recent degradation  in both BOD and TSS, but it
could not  be determined  whether this  was an actual decline in
performance  or  the result  of operator  inexperience  with lab
procedures.

    •    Case 51   '

This plant hired a properly  trained and certified operator who made
strong progress in cleaning up the effluents — making it compliant on
TSS. The plant  was originally  compliant on BOD but has further
                              27

-------
improved its performance on this measure. (This case is the same as
Case No. 11 in the Operation Cleansweep Survey.)

         c.   Findings from  the  District  Supervisors  Survey.
Among the 51 cases cited by the district supervisors as demonstrating
performance  improvement through training, a number of common
patterns were observed. These are categorized in Exhibit 2.

In nearly  all of the cases — 48 of  51  — training served  to boost
operator morale, attitude, or motivation for his job. Such changes are
rated as "General Improvement" in Exhibit 2.

Attitude changes alone have yielded significant benefits. As one town
manager put  it,  "I can get honest and informed answers from
operators who are more sure of themselves. They can tell me their
problems, and they can work  more  effectively with the consulting
engineers when they need to be called in to solve plant expansion or
design problems. Without  the  knowledge  gained from  operator
training, these men  are  embarrassed  and defensive about their
operation of the plant and consequently much harder to understand
and work with."

A second aspect  of the better attitude  is a generally cleaner plant.
One of the most frequent comments  heard was that the operator, or
supervisor,  upon his return from school, had policed the grounds and
brightened  up the plant through washing, painting, and renovating
the buildings and other facilities.

In the "Other Improvement" category on Exhibit 2, at least seven
plants  had decided to carry on  their own  lab work as a  result  of
operator attendance  at  a lab school.  This is  the only  area  of
substantial  operating cost reduction resulting from training that was
observed during the study.  It was reported by a number of WQB
representatives and  plant operators that lab work, when performed
by an outside source, costs, on an average, about $600 per year on a
contract basis. If  the trained operator performing his own laboratory
work spends as much as $100 per year on supplies and equipment, he
will be saving most of this contract amount — a sum representing a
substantial  and  ongoing return on  investment in his laboratory
training.

Two plants which appeared in the "Other  Improvement" category
have managed to employ some innovative tactics to benefit their
operations. One  was  converted  to  a  no-discharge plant by  the
addition of a pond, and the other found a market in irrigation for its
                              28

-------
                       EXHIBIT 2
SUMMARY OF WQB SUPERVISOR SURVEY CASE ANALYSIS
Case
1
1
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Became
Compliant
-
-
-
-
-
-
-
X
-
-
X
X
-
-
-
X
X
-
-
-
-
-
-
-
X
Improved
Effluent
Quality

X

X
*
*
X
X
X
**
X
X
X
X
X
X

*

X

*
*
X
X
General
Improvement
X
X
X
X
X
X
X
X
X
X
X
X
X
X
-
X
X
X
X
X
X
X
X
X
X
Other
Improvement
-
-
-
X
-
-
X
X
-
X
-
X
-
-
X
X
-
-
-
-
-
-
-
-
-
Comment



Developed irrigation market
source for effluent


Independent lab capability


Independent lab capability

Independent lab capability


Independent lab capability
Independent lab capability









  *No-discharge facility.
 **Self-reportirg data not complete.
                           29

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                        EXHIBIT 2 (Cont'd)
Case
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
Became
Compliant
X
-
X
X
-
X
X
X
-
-
X
-
-
X
-
X
-
-
-
X
-
X
X
X
-
X
Improved
Effluent
Quality
X
X
X
X
*
X
X
X
X
*
X
**
X
X
X
X
X
*

X

X
X
X

X
General
Improvement
X
X
-
X
-
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Other
Improvement
-
-
-
-
X
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
X
-
Comment




Conversion to no-discharge facility



















Independent lab capability

 •No-discharge facility.
"Self-reporting data not complete.
                                   30

-------
effluent. These approaches benefit the public because the effluent no
longer enters public waters, but they do not directly indicate plant
performance improvement as a result of training.

Of the 51 plants mentioned by the WQB district supervisors as having
experienced training benefits,  10 were either no-discharge facilities or
reported inadequate effluent data during 1971 to permit quantitative
performance assessment. Of the remaining 41 plants, 33 experienced
marked improvement  in effluent quality; 17 of the plants whose
effluent improved also  became compliant on both BOD and TSS
following operator training, as indicated on Exhibit 2. (Two of the
plants that improved  effluent quality  and became compliant had
been called before the WQB as part of Operation Cleansweep in the
first three months of 1971.)

Summarizing these results, of 51 plants which were  identified as
having benefited noticeably from training:

         (i)   Two cited for noncompliance by Operation Clean-
              sweep in  early  1971 became compliant; 15 more not
              cited by  the WQB improved their operations from
              noncompliant to compliant. A total of 33.3 percent
              of the  sample  became compliant on  both BOD and
              TSS following training.

        (ii)   Thirty-three (64.7  percent of the sample), including
              all  17  in (i)  above, experienced  improvement in
              effluent quality.

        (iii)   A  total of  48 plants — 94.1  percent - experienced
              "General  Improvements" of noticeable proportions.

        (iv)   Nine plants — eight of which experienced at least one
              of the above benefits — experienced "Other Improve-
              ments" (including two  that modified their plants to
              prevent them  from discharging effluent into public
              streams).

(In  this summary, the total  benefits  listed  exceed 51  in number
because of multiple effects experienced by individual plants.)
                              31

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B.   The  Impact  of  Training  in  Sustaining  High  Wastewater
     Treatment Plant Performance

The  influence of training  as a  factor in sustaining high levels of
treatment  plant  performance was explored through  a computer
correlation analysis for 124 wastewater treatment plants between
levels of  performance of  various  factors  representing number of
operators  employed and number of trained and certified operators
who exercised a direct influence over the operations of each plant.

     1.    Correlation Data Base

Three types of data were acquired for correlation in this analysis:

            — Plant performance.

            — Operator staffing.

            — Operator training (certification).

The Texas WQB maintains a "self-monitoring" system to which every
plant licensed by the  state that discharges effluent into a  public
stream or waterway must  report monthly. These  reports contain
information  on  many  items  of plant  performance, including
maximum  and average flow experienced by  the plant; bypassing
activity, if any; the percent of effluent discharged to public waters;
and  the maximum and average BOD and suspended  solids  in the
effluent in parts per million. The report from each plant is fed into a
WQB computer which produces printouts of plant performance data
over a running 12-month period for  all plants, both municipal and
industrial. (This investigation concerned  itself only with municipal
plants.) A typical entry for one plant in the WQB is shown in Exhibit
3.

As a basis for selecting a sample for the correlation analysis, four
criteria were established:

          (i)   Size between 1.0 and 20  million gallons per  day
              design capacity.

        (ii)   Accurate performance  data available for at least six
              months of 1971.

        (iii)   Operator staffing information independently available
              (see below).
                              32

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                                              EXHIBITS
                                   TYPICAL PLANT ENTRY IN WQB
                              SELF-MONITORING COMPUTER REPORTS
u>
REPORT DAYS  DAYS VOL-MAX
 DATE  DISC BYPASS BYPASSED
 GALENA PARK CITY OF
ri-7i
02-71
"3-71
04-71
P5-71
"6-71
C7-71
11-71
n^-71
10-71
11-71
12-71
31
28
31
30
31
3"
31
31
30
31
30
31
oo
00
CO
00
00
00
00,
00
no
00
oo
00
FLOW-HAX
 HG/OAY
                           .400
                           .600
                           .$ni
                           .350
                           .440
                           .360
                           .340
                           .310
                           .40"
                           .300
                           .500
                           .320
REQUIREMENTS
W-AVF
/DAY
VOL
RELEASED
10031-01
.330
.340
.350
.300
.300
,?ซP
.250
.225
.750
.750
.290
.250
.700
100
100
10P
100
100
100
100
100
100
100
100
too

BOD
MAX
PLANT
Q
B
7
29
26
13
6
1*
R
4
R
2
30
BOD
MOAVE
NO 1
9
8
6
23ป
21*
R
6
10
5
It
a
2
20
TSS
MAX

18
14
9
41*
38*
21
6
6
7
11
10
7
30
TSS
MOAVE

15
11
7
30*
27*
15
4
5
6
8
7
6
20
CHL-RES
HIN

2.0
2.0
2.0
2.0
2.0
2.0
2.0
2.0
1.0
2.0
2.0
1.0
1.0
CHL-RES
HOAVE

2.0
2.0
2.0
2.0
2.0
2.0
2.0
1.4
2.0
2.0
2.0
2.0
1.0
STA
HIN

50*
37
37*
37*
37*
21*
21*
21*
50*
60*
50*
50*
95
STA
MOAyE,

60*
53
58*
50*
40*
37*
40*
40*
55*
65*
65*
65*
95
S-SO
MAX

*






4




2
                                                                                                      S-SOL  SPEC
                                                                                                      HOAVE  PROV
                                                                              NA
                                                                              NA
                                                                              NA
                                                                              NA
                                                                              NA
                                                                              NA
                                                                              NA
                                                                              NA
                                                                              NA
                                                                              NA
                                                                              Nป
                                                                              NA
                                                                                                        3

-------
         (iv)  Operator  training (certification) data independently
              available (see below).

A total  of 124 plants  out of a  state population  of  over 1,200
discharging facilities fulfilled these four requirements.

Operator staffing information — the number of operators employed
full or part-time — was taken from  manpower surveys performed for
the Environmental  Protection Agency and Department of Labor in
1971, and certification data were taken from the Texas Department
of Public Health records. Certification data were used, in this study,
as a surrogate or indicator of operator training because of the direct
connection  between the two under Texas licensing regulations and
the lack of readily usable data on training itself.

In Texas, operators are certified at four different levels,  as shown in
Exhibit 4. The B, C, and D operators, to maintain their  certificates,
have to  have achieved  the directly related training shown under
"Renewal Provisions" in Exhibit 4. Thus, a D operator has to have an
average of five hours per year training; a C, 6 2/3 hours; and a B, 10
hours simply to maintain their status. Furthermore, the training that
is accepted  for credit under this plan is approved by a professional
committee within the state which insists that the training be directly
related  to  job  responsibilities,  not just generally  applicable. The
operators who  have  currently  valid certificates  can therefore be
considered to be trained — and in fact recently trained — operators.
Those  who  do not possess certificates, of course, may  be  partially
trained,  and those  who do have them  may be trained above the
minimum levels — in effect on their way to a higher level. Therefore,
although the existence of a certificate is not a precise measure of the
level of training, it is, we feel, a reliable indicator of the existence of
training.

     2.   Computer Correlation Analysis

The computer  correlation study,  based  upon the inputs above,
revealed  that  both  staffing and training did influence plant opera-
tions and that it influenced some types of plants more than others.
Heavily loaded  plants were apparently  affected more than lightly
loaded ones, and activated sludge plants more than biological filter
plants.

The first step in the analysis was the calculation of a correlation
matrix to determine which parameters of performance, staffing, and
training seemed to  be related. In the matrix, a series of correlation
                               34

-------
                                    EXHIBIT 4
          OPERATOR CERTIFICATION REQUIREMENTS IN TEXAS
Class
A

B

C

D
Requirements
Education Masters Degree
Experience 4 yrs. o
Training 160hr.
Education Bachelor Degree
Experience 1 yr. c
Training 60 hr.
Education 1 -year College
Experience 2 yrs. o
Training 0
Education HS/GED
Experience 0 <
Training 1 0 hr.
Bachelor Degree ( 2-year College
r 5 yrs. or 6 yrs. (
160hr.
HS/GED
r 3 yrs
lOOhr.
HS/GED
r 3 yrs. o
0
160hr.


HS/GED
r 2 yrs. <
20 hr.
Less than HS/GED Less than HS/GI
r 1 yr. or 0
1
0 , 20 hr.
HS or GED
r 8 yrs.
160hr.


HS/GED
r 1 yr.
40 hr.
D
Renewal
Provision
NONE


SO hours in
5 years

20 hours in
3 years
10 hours in
2 years
Source:  Texas State Department of Health, Division of Sanitary Engineering, Rules and Regulations Covering the
       Certification of Water Utilities Personnel, adopted by the Texas State Board of Health, September 12,
       1966, revised June 8, 1969, and December 12, 1971.

-------
coefficients was calculated which indicated the apparent relationship
existing between pairs  of parameters.  If  a nearly perfect linear
correspondence existed,  the coefficient approached + 1.0000; if very
little relationship existed, the coefficient approached 0.0000. For
purposes of this analysis,  we have assumed that strong correlations
exist where  the coefficient is 0.7 or more, that weak to moderate
relationships  are represented by coefficients  between 0.4 and 0.7,
and that no meaningful relationships exist if coefficients are below
0.4. A positive coefficient indicates that the variables are moving in
the same direction and a negative one that the variables are moving
inversely to one another.

The parameters  of performance, staffing, and training used in the
analysis include the following:

         PER  1 — BOD performance;  the  inverse  ratio of BOD
              achieved  to BOD  permitted,  resulting  in a higher
              number as performance improves.

         PER 2 - TSS performance, calculated like PER 1.

         LOADING — Plant load; the average flow  divided by the
              WCO-permitted flow, resulting in a fully loaded plant
              exhibiting 1.0, overloaded plants more than 1.0, and
              underloaded plants less than 1 .0.

         OPL — Operator staff; the number  of operators (whether
              or not certified) per plant.

         INT — Staffing  intensity;   the  number  of  operators
              (whether or  not certified)  divided  by  the average
              flow.

         TI,  T2, TS,  T4 - Certified  operators; the  number  of
              operators  per plant at the  D, C, B, and A levels,
              respectively.
         TlA> T2A. TSA, T4A — Certified operator intensity; the
              number of operators certified at each level divided by
              the permitted flow.
         TIB,  T2B, TSB, T4B - Certified operator intensity,  cal-
              culated as above but divided by the average flow.
                              36

-------
          TIC,  T2C, TSC, T4C - Certified operator density;  the
              number of certified operators at each level, divided
              by OPL, the number of operators employed.

          TReq,  TB,  TC — The values for the sum of certified
              operators at all levels divided, respectively, by per-
              mitted flow, average flow, and  operators employed.

          TlND - Training  index;  an  index  of  the numbers of
              certified operators,  weighted according to average
              training hours required for each level of certificate,
              divided by permitted flow  TI + 2T2 + 4Ts + 8T4
                                            Required Flow

The A  sample matrix presenting correlation coefficients for over-
loaded trickling  filter plants between various pairs of these and other
factors  is presented in Exhibit  5. Coefficients used in later analyses
are flagged.

The computer correlations yielded the data  shown in Exhibits 6, 7,
8, and 9. Exhibit 6 shows to what extent performance, represented
by PER 1 and PER 2, correlates with staffing levels, as represented
by INT. Applying  the above criteria for identifying the strength of
correlations from these data, we find that there  appears to  be a weak
to  moderate correlation between number of operators and perfor-
mance  in overloaded trickling filter plants and  in  fully loaded
"other" plants (at least in the removal of suspended solids). On  the
other hand, the performance of activated sludge plants operating at
more than 50 percent of rated  load and moderately loaded "other"
plants appears to  be inversely  correlated  (at  weak  to  moderate
strength)  with number  of operators.  These findings suggest that
overloaded biological filter plants and fully loaded other  plants  are
more labor  intensive  than activated  sludge plants and  that  the
addition of labor in those plants, whether or not trained, will help
performance to a degree.
Exhibit 7  shows the correlation coefficients for TIA, T2A,
T4A, and TReq with PER  1 and PER 2. These represent the extent
to  which  performance  correlated with  the number of  certified
operators at each of the four certification levels and in relation to
total permitted gallons  of  flow per day. From these data, it can be
seen that certified operators appear to be slightly more influential (as
judged by the frequency  of positive correlations observed) in  the
operation of activated  sludge plants (7 positive correlations above
0.4)  than  in the operation of either trickling filter (4  positive
                               37

-------
                          EXHIBIT 5
       SAMPLE COMPUTERIZED CORRELATION MATRIX
              (For Overloaded Trickling Filter Plants)
CORRELATION MATRIX:
                          - Performance Parameter*.
FLO
1 PER 2 1-*-*
FLO


REQ


BOO


Ttt


OPL


LAB


S
1.0000
-0.4647
03684
03898
-04198
0.1187
03459
-04053
-0.1499
05197
0.4483
-0.1880
03377
-0.4762
0.3340
0.8827
-03973
05273
03184
J- 0.4296
0.104
0.0
ซ• 0.0
*• OjO
T1A J 0.0
jฃ OjQ
uj 1031 n.a.
T2


T2A


T3


T3A


T4


T4A


TREQ


TB


BODREO


TSSREO


PERI


PER 2

0.8903
0.3433
03333
•0.4647
13000
104304 1
02096
-0.3948
-03929
-03239
- 0.1757
1-03882 1
05696
-05019
-0.1994
03919
• 03485
1-0.27401
-0.4998
0.1983
1- 0.13621
-0.4994
03178
1-056731
05463
03407
0.7420
0.5661
0.1469
0.7277
-03036
0.3469
0.6561
0.0564
04304
. 15000
TIHD | -03653
S -0.1017
U- -03761
TIND1 ซฐ -04328
2 05458
ฃ -0.1960
LOADING JS 0.1122
-03622

INT


TIB


T2B


T38


T4B

• 03014
-03253
- 0.0695
05167
OJO
QXI
IQjOl IM,
-04438
05729
[7331741
-03313
-0.1898
1-038081
03368

I- 03512 1
REQ
P 	
TIHD
05898
03095
-0.3663
1.0000
03364
-03440
03383
03042
-03745
05078
03456
-03433
03699
0.1775
-03370
0.7340
0.4868
-0.0822
03431
0.1433
-03756
0.0
0.0
0.0
OJO
0.0
0.0
0.6552
-0X1101
-0.3843
-04196
-0.3948
-0.1017
03384
1.0000
0.7824
-0.3024
0.7898
05727
03128
0.1898
-0X1774
03498
0.1090
0X1330
-04633
0.6407
. 05486
-0.4504
03353
03349
0.0823
-0.1892
-0.1795
03174
0X1955
-03035
-0.1760
-0.1633
-0X1272
0.1187
-03929
-03761
-03440
0.7624
1.0000
-04010
0.7129
03642
03005
-04811
-0.4657
-0.1518
0.1779
0.1921
0X1
05
0X1
-03821
• 03337
• 0.0525
• 03066
0.7922
0572S
03102
0.1103
0X1611
JOB-—
T3A
TIND1
03459
0.3238
-0.4328
03393
• 03024
-0.4010
1.0000
•03663
-0.3601
03621
-03146
-03179
0.6968
-03048
-0.4161
03818
0.0388
•0.0273
0.7372
-03437
-0.4451
0.0
0X1
0.0
0.0
0X1
03
03667
-0.3985
-03253
-0.4053
-0.1767
0.0459
03042
0.7898
0.7129
• 0.2663
1.0000
05753
0.6139
-0.1797
-03949
03507
-0.1089
-03330
-04057
05242
05823
-04105
03059
03681
05390
-03050
- 0.1316
03203
•0.1858
• 0.15E8
-04370
-0.0194
03578
-0.1499
-03882
-0.1960
-03745
03727
05642
-03601
05753
1.0000
03146
-04007
• 0.4654
-03532
0.1816
0.1687
05
0.0
05
-03800
-0.1339
0.0823
-03773
03985
05752
03974
-0.0841
-03030
TSS
T4
LOADING
05197
03696
0.1122
03076
03128
03005
05821
05139
0.0146
15000
0.5717
0.0256
0.7054
03340
-03673
03705
-05330
-03639
0.7466
03459
0.0628
0.0
0.0
03
0.0
05
05
03624
0.0251
-03829
-0.4463
•03019
-03622
0.3456
0.1898
-04611
-03146
- 0.1797
-04007
05717
13000
0.1559
03060
03279
0.0462
-03785
-03985
• 05196
• 03848
-03146
-0.6136
0.0272
-0.1410
-0.1926
03999
-0.0101
-03161
-0.3437
-03898
•03366
-0.1680
-0.1994
-03014
-03433
-05774
-04667
- 0.3179
-03949
-0.4654
0.0266
0.1559
1.0000
-03171
-0.0974
•0.4275
05
0.0
0.0
-04287
-04758
-0.4241
-03222
-0.1901
-04268
03470
0.7582
-05109
OPL
T4A
INT'
03377
03919
-03253
03699
03498
-0.1618
0.6988
03807
-03532
0.7054
03060
-0.3171
15000
03326
03862
03721
-0.1985
0.0174
03144
03996
0.1114
0.0
03
0.0
0.0
03
03
03613
-03200
• 0.0118
- 0.4762
•03465
-0.0695
0.1775
0.1090
0.1779
-03048
-0.1089
0.1816
03340
03279
-03974
03326
13000
0.0689
-04802
-03236
0.1627
•04398
-03202
03465
03453
• 0.1622
0.4321
05730
-0.1590
0.1979
0.0219
-03179
05107
03340
•03740
03187
-0.3370
0.0330
0.1921
-04161
-03330
0.1687
-03573
05462
-0.4275
03862
0.0689
1.0000
03
03
03
-03942
-03032
05600
-03021
-0.1090
03087
0.3099
0.9898
0.1241
LAB
TREQ
TIB
0.6927
•04998
03
0.7340
-0.4633
05
03616
-0.4057
05
03706
-03785
05
05721
-04802
05
13000
-0.1207
05
03694
-03031
03
0.0
0.0
0.0
05
0.0
0.0
05554
• 03783
0.0
-03973
0.1983
0.0
0.4868
0.6407
05
05388
05242
05
-0.0330
-03985
0.0
-0.1985
-03236
0.0
• 0.1207
1.0000
03
-0.0913
03906
0.0
05022
- 05770
0.0
05554
-0.1446
05
• 03520
0.0935
05
03273
-0.1382
0.0
-03822
05486
05
-05273
03823
0.0
-03639
-05196
05
05174
0.1627
05
03
05
05
• 03614
03344
05
05S26
05254
0.0
• 0.1930
• 0.1901
0.0
S
TB
T2B
03184
•04994
-04436
03431
-0.4504
-03821
0.7372
-0.4105
• 0.3800
0.7465
-03848
• 04287
05144
-04388
• 03942
03594
-0.0913
-03614
13000
-04817
-03966
05
0.0
0.0
0.0
0.0
0.0
05334
-03367
03824
-0.4296
03178
05728
0.1433
0.6353
-03337
-03437
05069
-0.1339
03459
-03145
-04758
03996
•03202
-03032
-05031
03906
03344
-04917
15000
03808
0.1410
-0.0083
04395
04815
-03942
03175
• 0.1020
0.1597
04148
0.1834
-05673
05174
-03758
05349
• 0.0525
-04451
03681
03823
03628
-05136
• 04241
0.1114
03465
0.0600
03
0.0
03
-03966
03808
1.0000
-03394
05121
• 0.1239
03729
- 0.1814
• 0.4787
Tl"
BODREQ
T38
03
03483
• 03313
05
03823
•03086
03
0.0390
-03773
05
0.0272
-03222
03
03453
-03021
05
05022
03526
05
0.1410
-03394
05
0.0
0.0
05
05
0.0
05
05306
-03935
05
03407
-0.1899
0.0
•0.1692
0.7922
0.0
-03050
03995
05
-0.1410
-0.1901
03
-0.1622
-0.1090
05
-05770
03254
05
-0.0083
05121
05
1.0000
• 0.1930
05
03273
- 0.179G
03
0.6070
0.0090
03
0.7420
-03806
05
-0.1795
05725
05
-0.1316
05752
05
-0.1826
-04268
05
04321
03087
0.0
03
05
03
0.4395
-0.1238
05
- 0.1930
13000
05
-0.1771
- 0.0821
itsBiU-*-
T48
03
03651
03388
03
0.6174
03102
05
03203
03974
05
03999
03470
05
05730
03099
05
05554
-0.1930
05
04815
03729
03
0.0
03
05
03
0.0
05
0.7899
-03284
05
0.1459
• 03248
05
05955
0.1103
05
-0.1858
-05841
05
-0.0101
0.7582
0.0
-0.1590
05898
03
-0.1446
- 0.1901
05
-03942
• 0.1814
05
0.6273
• 0.1771
05
1.0000
-0.1544
05
03423
-03318
03
0.7277
-03532
05
-03035
03611
05
-0.1558
-03030
05
-03161
-05109
03
0.1979
0.1241
03
05
0.0
0.0
03175
-04787
05
• 0.1796
-05821
0.0
• 0.1544
1.0000
T2 	
PER 11

03903
-03038

0.6552
-0.1790

05567
• 04370

05624
0.3437

03613
05219

05554
-03520

05334
-0.1020

05
0.0
	
lojlnj.
05

15000
0.1255

03433
1034501

•05101
-0.1633

.03966
1-051941

03251
-03298

-03200
1-031791

-03783
1 0.09361

-03367
1 0.1597 |

03306
0.6070

0.7899
03423

0.1255
13000

03333
03551

-03943
-0.0272

-03253
05676

-03829
-03386

-05118
05107

05
1051 UJ.

03824
1 041481

-03936
1 OXI090~

-03294
1-03318

                            38

-------
                        EXHIBIT 6
                 INT:PER CORRELATIONS
                   No. Operators Employed
                       Average Flow


Overloaded
(100%+)
Fully Loaded
(75%- 100%)
Moderately Loaded
(50% - 75%)
Lightly Loaded
(10% -50%)
All
Trickling Filter
PER 1
ฉ
-.15
.02
.06
.16
PER 2
ฉ
0)
.07
-.11
.10
Activated Sludge
PER 1
'M'n'Pfa

ฎ
.12
.01
.04
PER 2
rfK-fiEaM! :

.03
ฉ
-.35
.01
Other
PER 1 1 PER 2
1*0 *fc
.24
<^50)
-.27
-.23
t&Sftr*'
(]69)
.07
-.13
-.03
AD
PER 1





PER 2





Key

I   I   Strong Correlation

      Weak to Moderate Correlation
                           39

-------
                          EXHIBIT 7
                   TA:PER CORRELATIONS
                     No. Certified Operators
                          Permit Flow


Overloaded
(100%+)



Fully Loaded
(75% -100%)



Moderately Loaded
(50% - 75%)



Lightly Loaded
(10% -50%)



All




Trickling Filter
PER 1
D n.a.
C .35
B -.02
A -.32
All .09
D -.04
C -.13
B .07
A .02
All -.10
D .08
C -.09
B ;i3
A .20
All .01
D -.23
C -.08
B -.33
A -.25
A1K2T
D .06
C -.01
B -.04
A -.10
A11-.03
PER 2

Q|}
-.i9
-.27
-.14
-.23
-.36
.29
.05
72T
p7o|
7T5
.02
-.03
T7
dD
-.15
-07
(^47)

-.26
-.22
-.20
T24
-.21
-.18
-.15
-.12
7T7
PER 2


ts^taw ;


Ws
C-52)
.08
.25
-34-
.„
Ez3
13
-27
^67)
-.31
-.17
-.10
-.09
TTT
-.22
-.06
-.06
-.08
-ToT
All
PER 1

























PER 2

























 Key

 I   I   Strong Correlation

(^__^)  Weak to Moderate Correlation

 n.a.   Not Available
                            40

-------
correlations) or "other" plants (3 positive correlations). The number
of  certified  operators  at  the  D level — a minimum level — does
appear, however, to influence  the removal of suspended solids in
trickling filter plants.

In this run, as in subsequent runs, a number of weak to moderate
negative correlations also appeared, suggesting that there appears to
be an inverse relationship between T and PER, rather than a direct
one. This inverse relationship would  say that PER is higher in plants
with fewer certified operators per unit of permitted flow. We believe
that this is  true, in fact, of certain  parts of the sample because of
individual  characteristics  of the plants — in  specific  size, type,
loading, or  location — and the ability of their managers,  but the
general conclusion  that performance can  be positively correlated
with the  number  of  certified operators survives because  of the
preponderance of positive correlations.

In Exhibit 7 it  appears also that the  presence of  D  and  C level
operators  (4 positive correlations above 0.4  each) correlates with
performance more clearly than the presence of A and B operators (2
and  0  positive correlations, respectively).  The use of the  ratio of
certified operators to permitted flow (T]A, TIB, and so forth) to
correlate with performance  was  a  first pass at the  analysis  and
revealed that introducing certification levels in the "T" parameters
tended to improve the frequency of correlations over those found (in
Exhibit 9) using pure staffing data (INT).

Because the ratio of certified operators to permitted flow might not
give the best correlations, however, we looked at two other possible
parameters:  Tfi  (1B-4B)  TC  (C1-C4),  which were ratios  of the
number of certified operators to average yearly plant flow and to
number of  operators on the staff (OPL), respectively. In the first
case, the number of operators was divided by  average flow to adjust
for any difference  in  the  extent of plant loading in  the sample,
largely in the belief that plant hiring practices would probably more
closely match the experienced load (or overload) rather than the
permitted load.  In the second case, we were trying to separate the
effect of training certification level  from the effect  of numbers of
staff. In the TA and TB measures, the operator that  is counted is a
trained and certified operator,  but he is also an operator who may
already show up in the staffing measures of OPL and INT. Thus, TA
and TB measure the presence of trained and certified operators — in
essence, the presence of both training and staff. The  TC measure,
however, takes the ratio  of trained and certified operators to all
operators, thus proportion of a given staff that is trained.
                              41

-------
Exhibit 8 shows the results of the TB correlations with PER. In these
data,  more  significant  correlations  appear to exist, one  negative
correlation disappears, several positive correlations are stronger, and
two negative correlations are weaker than the previous analysis. Plant
performance, therefore,  appears to correlate more closely (as judged
by the frequency and magnitude of the correlation index) with the
ratio of trained and certified operators to average plant flow.

Exhibit 9 shows the correlation values using the TC ratios  which
were introduced to try  to separate the effect of training from the
effect of staffing. This exhibit shows still further improvement over
the earlier date. Correlations in the case of overloaded trickling filter
plants  have  disappeared, but new and/or much stronger positive
correlations  have  appeared in the  activated sludge and  "other"
categories.  Because  of  the greater frequency of  correlation, we
calculated and presented on this exhibit the figures  for all plants, of
all types and sizes. The  relative frequency of  correlation of the TA,
TB, and TC ratios with performance is shown in Exhibit 10.

The TC measure — an indicator  of the  proportion of the staff of a
plant that has been exposed to training — is the best determinant of
performance that  we have found. Where performance is high, the
training  level  of  the  staff is the most likely  reason. Although
successful plant operation correlates to some degree with size of
staff, it seems to be much more directly related to training achieved.

If training is the major reason for sustaining good performance, the
performance of plants that improve should be  explainable in terms of
training as well. Section A, above, presents  a case-by-case view of
how training can improve plant performance. To test quantitatively
the hypothesis that training relates to performance improvement, we
divided our sample of 124 plants into three groups:

         (i)  Those  plants  whose  performance on BOD or  sus-
              pended  solids removal declined by  10  percent or
              more in  1971, as measured  by  a comparison of
              performance figures for the first  three months  and
              the last three months of 1971.

         (ii)  Those plants whose  performance stayed roughly the
              same  (that is, within +10  percent  during 1971, as
              measured above).
                              42

-------
                         EXHIBITS
                  TfirPER CORRELATIONS
                    No. Certified Operators
                        Average Flow


Overloaded
(100%+)



Fully Loaded
(75% -100%)



Moderately Loaded
(50% - 75%)



Lightly Loaded
(10% -50%)



All




Trickling Filter
PER i
D n.a.
C (AT)
B In
A -.33
All -.16
D -.03
C -.10
B .14
A .05
All -.03
D .08
C -.01
B .19
A .20
All .11
D -.23
C -.06
B -.14
A -.21
All -.11
D .05
C .05
B .04
A -.03
All .06
PER 2

cfb
^58
-.25
-.07
-.20
-.33
.35
.08
-.19
@
.19
.06
-.03
.33
(!52)
-.08
11
t46)
-.03
Cli)
.13
.02
-.17
.14
Activated Sludge
PER 1


ซft*Sw


dP
.17
,2&
G4U

n.a.
-.20



HA
Q€>
-jf
(csSOj)
oS>
.09
.30
-.14
.37
.36
PER 2
'

J&CTttfr





-•28
tzil
n.a.
-.26
-71
CscD
-.10
n.a.
.20
-.31
-.18
.07
.08
.34
-.27
.13
.31
Other
PER 1


Hfe F*w


n.a.
.17
-.33
.26
.34
-.02
-.36
-.24
-.20
(^43)
-.30
-.23
-.22
-.22
-.23
-.17
-.14
-.13
-.12
-.13
PER 2


fKl&fo


ija.
Qt>
.08
.25
.36
,7
[OTO)
.OS
-.26
C!E>
-.22
-.17
-.14
-.14
-.16
-.15
-.11
-.10
-.10
-.10
All
PER 1

























PER 2

























Key
      Strong Correlation

      Weak to Moderate Correlation

n.a.   Not Available   -
                           43

-------
                                EXHIBIT 9
                        Tc:PER CORRELATIONS
                          No. Certified Operators
                         No. Operators Employed
                   Trickling Filter
                   PERI
        TERT
               Activated Sludge
TERT
wfr
                                               PER
                                                   Other
                                                                  All
                                                       PER 2
                                                              PER 1
                                                                     PER 2
  Overloaded
  (100%+)
         n.a.
          .01
         ,27
         ,30
         -.27
  Fully Loaded
  (75%-100%)
D  .11
C  .14
B  .18
A  .29
                  All .26
                n.a.
                .07
                .14
                .26
                .10
  Moderately Loaded
  (50%-75%)
D  .07
C ,01
B  .07
A  .16
All .03
                n.a.
                ,28
                ,27
                ,35
                ,34
  Lightly Loaded
  (10%-50%)
D -.23
C  .10
B -.01
A ,29
All .01
                -.30
                .20
                .33
                .24
                .26
  All
                  D .04
                  C .03
                  B -.02
                  A ,12
                  All .00
                 .09
                 .33
                 -.24
                 .34
                ^32
                ,15
                -.07
                .08
                ^06
                ,01
                       .05
                       .08
                       -.07
                       .25
                       .06
 .24
 .30
 .08
,00
 .28
 Key

 I	j    Strong Correlation

(^^)   Weak to Moderate Correlation

 n.a.     Not Available
                                    44

-------
                    EXHIBIT 10
    RELATIVE CORRELATION FREQUENCIES BETWEEN
      TA, Tfi, and TC FACTORS WITH PERFORMANCE
Positive Correlations
Strong
Moderate
Negative Correlations
Strong
Moderate
Total
TA:PER
Exhibit 7
14
3
11
6
0
6
20
Tfi:PER
Exhibit 8
17
5
12
4
0
4
21
TcC:*PER
Exhibit 9
27
10
17
4
0
4
31
*Without consideration of "all types" column in Exhibit 9.
                         45

-------
        (iii)   Those  plants whose performance improved  by 10
              percent or more in BOD or suspended solids removal
              in 1971 as measured above.

For each of the three groups, we then computed mean figures for TB
values first and the training index of TIND and produced the results
shown in Exhibit 11.  Exhibit 11 shows that the plants that made a
10 percent or better  improvement in performance in 1971 had, on
the average,  significantly  higher values of TB and a significantly
higher training index than plants which stayed the same or achieved
worse performance. (We have  been unable to satisfactorily explain
why those plants that stayed the same, in many cases, have lower T
values than those whose performance degraded.)  Exhibit 12 shows
the relative values of these correlations using the "worse" cases as the
standard. In  every  training measure, the  "better" case has higher
training parameters, ranging from  1.3 to 40.0 times as high as the
worse case, whereas in no case is the effect of staffing  (INT) as
important.

C.  Conclusions  Regarding the Impact of Operator Training on
    Plant Performance

Examinations of  case  studies  of plants involved  in Operation
Cleansweep and plants cited by  WQB district supervisors as having
experienced training benefits provided strong indications that train-
ing has  had a  strong  beneficial influence  in improving  plant
performance  in a significant proportion of plants whose performance
has been  historically substandard. In addition,  the potential for
training benefits in plants encumbered by  inadequate facilities is
great and may be expected to be realized when physical obstacles are
removed.

A computer correlation  study  of a sample of Texas wastewater
treatment plants, conducted independently of the earlier two studies,
showed that the  proportion of  the staff of a plant that  has been
exposed to training is the best  determinant of performance, both for
plants  with sustained records  of good performance and for plants
that made  a 10 percent or better improvement  in performance in
1971.

As a result of these separate studies, we may conclude that training
bears  a direct  and measurable  relationship to plant performance
improvement as well  as to plant performance levels. Both of these
relationships  could have been explored further with greater data
availability (on all plants in Texas) and additional study resources. It
                              46

-------
            EXHIBIT 11
CHANGES IN PLANT PERFORMANCE WITH
TRAINING AND STAFFING PARAMETERS
Parameter
TlB(D)
T2B(C)
T3B(B)
T4B(A)
TB(A11)
INT
TIND
BOD
Worse
.0006
.0150
.0120
.00008
.02768
.0081
6.186
Same
.0003
.0140
.0062
.0005
.0210
.0101
5.160
Better
.0011
.0400
.0200
.0032
.0643
.0109
10.043
TSS
Worse
.0009
.0200
.0100
.0010
.0319
.0134
6.858
Same
.0001
.0085
.0072
.0005
.0163
.0081
6.606
Better
.0012
.0520
.0270
.0038
.0830
.0076
10.950

-------
                                       EXHIBIT 12
                                   RELATIVE VALUES OF
                      CORRELATIONS OF CHANGES EM PLANT PERFORMANCE
                          WITH TRAINING AND STAFFING PARAMETERS
00
Parameter
TlB(D)
T2B(C)
T3B(B)
T4B(A)
TB(All)
INT
TIND
BOD
Worse
1.0
1.0
1.0
1.0
1.0
1.0
1.0
Same
0.5
0.9
0.5
6.2
0.7
1.3
0.8
Better
1.8
2.7
1.7
40.0
2.3
1.3
1.6
TSS
Worse
1.0
1.0
1.0
1.0
1.0
1.0
1.0
Same
0.1
0.4
0.7
0.5
" 0.5
0.6
1.0
Better
1.3
2.6
2.7
3.8
2.6
0.6
1.6

-------
the  plant  was brought  before the WQB, the operator was  an
uncertified part-time employee. Operator training recommended by
the Board was under way at the close of 1971, but the results of
training had not yet materialized at the time this report was written.
The WQB expects good performance from this plant in 1972.

     •   Case 11

At the beginning of 1971, this plant was seriously noncompliant on
BOD and TSS and was not self reporting. During 1971, the hiring of
a trained and certified operator has caused dramatic improvement in
both performance areas, although the plant  is not yet compliant on
TSS.

     •   Case 12

The Case 12 facility was an older plant, in deteriorated condition,
that was noncompliant on BOD and TSS. During 1971, some repairs
were made, and the town initiated action to acquire a new plant. The
potential for training impact after addition of new facilities is strong.

     •   Case 13

This  town  has three small  plants,  all of  which  are seriously
overloaded and seriously noncompliant on BOD and TSS. Subse-
quent to the WQB hearing, the town decided to join a regional plant
now in the planning stage. Training does not  appear to have a bearing
on the problem or its resolution in this case.

     •   Case 14

The plant in Case 14 was seriously overloaded and noncompliant on
BOD and TSS — in large part  because of a  sewer collection system
that was permitting excessive infiltration. During the year since the
Board hearing, the country has hired a consulting engineer to survey
the  situation.  On  the basis of this work,  improvement has been
noticed on both BOD and TSS. Training does not have a bearing on
this problem; however, a properly trained and experienced operator
might have been able to bring about significant improvement in lieu
of calling in a consulting'engineer.

     •   Case 15

This plant needed additional treatment facilities, including chlorina-
tion capability, and it was not reporting complete information on its
                              15

-------
self-monitoring reports. Because of its failure to respond to the
WQB's inquiries, this plant has been referred to the State Attor-
ney General's office for action. It should  be noted that the
WQB, through corrective proposals, makes an extended effort
to avoid such fines. Further, only in instances of complete un-
cooperativeness are these matters referred to the State Attorney
General's office. The  potential  for  training impact  after the
addition of new facilities is strong.
      •   Case 16

This overloaded plant was noncompliant on BOD and TSS and
was not sufficiently chlorinating its effluent. Improvement has
been effected in chlorine content of effluent and on TSS, but not
in BOD performance. Training does not appear to have an in-
fluence here.
          c. Findings  from the  Operation  Cleansweep Investi-
gation. The types of problems, solutions selected, and apparent
influence of training in resolving the 16 cases of noncompliance
with WQB  standards,  as  described above,  are summarized in
Exhibit 1. As shown, the performance of four of the plants that
were  in serious  violation  of their  state wastewater permits in
early  1971—or 25 percent  of the plants  brought before the
WQB in the first quarter  of  1971—was  improved significantly
at least in part through operator training. Two of these  plants
became compliant on both BOD and TSS*measures. The plants
that appeared most responsive to the influence of training were
those  characterized by poor operation  as  a result of lack of
operator knowledge, rather than those that were seriously over-
loaded.

In addition to  the cases identified as responding positively to
training, there  was one case—case 10—in which surveillance
authorities  observed  that the operator was just undergoing
training at the time of this report and anticipated the training to
yield  strong positive results. At least two other problem situa-
tions—cases 5  and 14, in which consulting engineers were re-
tained—might  have been  resolved  through  the hiring of a
properly trained operator.

Thus, from this sample of "problem plants" in serious violation
of pollution control standards, possibly as many as 45 percent
(seven out of 16)  exhibited problems potentially susceptible to
resolution through operator training,  and 25 percent (four out
of 16) effectively used training in resolving those problems.

     2.  WQB  District Supervisors' Survey

         a.  Overview. The survey of the WQB district super-
visors to determine which plants had noticeably benefited from
training began as a  telephone interview with each of the 12 district
                             16

-------
would have been useful, for instance, to vary the rate of performance
improvement to determine the precise relationship between training
and performance.
                               49

-------
                           PARTY
       THE RETURN ON THE PUBLIC INVESTMENT IN
 WASTEWATER TREATMENT PLANT OPERATOR TRAINING
Part IV  of this report concluded  that  training of  wastewater
treatment plant operators does have  several beneficial effects upon
the quality of plant effluent and efficiency of plant maintenance and
operations. The  formulation  of a  statement  of the  precise dollar
value of these benefits would be very difficult, if not impossible, and
it is not within the scope of this study to attempt to produce such a
statement. However,  it is possible from the study to develop some
quantitative insights into the value of training benefits that should be
useful to decision-makers considering the desirability of sponsoring
and/or conducting additional operator training.

The public investment required to initiate and support the effective
operation of a municipal wastewater treatment plant is substantial —
estimated in excess  of  $160 million in Texas. This investment is
made with  the expectations that capital plant will be utilized in such
a way  as to  maximize  the useful life  and that specified levels of
effluent quality will  be  achieved. Therefore, this part of the report
considers the value to the public of training benefits in terms of:

         (i)   The value of the capital assets entrusted to the care of
              individual operators.

         (ii)   The investment that is wasted when a treatment plant
              does  not  fulfill  its  BOD   and  TSS  removal
              requirements.

A.   Value of Capital Assets per Operator

The value of  the  capital assets  entrusted  to  individual  Texas
municipal wastewater treatment plant  operators was estimated by
calculating the operator population and capital  investment for a
random sample of plants in the state of Texas.  In most aspects of the
calculations, supplementary data were acquired with the  cooperation
of the Texas WQB.

     1.   Explanation of Calculations

To determine the   average  value  of  capital assets per operator
represented by Texas municipal wastewater treatment plants, using a
Kendall and Smith Table of Random Numbers,  a random sample of
                               51

-------
50 plants was selected from the EPA STORET information system,
which lists 993 separate municipal treatment plants in Texas. These
50 selected plants are identified in Column 1 of Exhibit 13:

Each of these 50 plants was then categorized by physical characteris-
tics  according to  nine  basic types of  conventional  wastewater
treatment plants listed in  the study, "Estimating  Costs and Man-
power  Requirements  for Conventional  Wastewater  Treatment
Facilities," prepared by Black  and Veatch, Consulting Engineers, for
EPA  in October  1971.  When  a  random  STORET  sample plant
indicated  a nonconventional plant type — that is, one that did not
correspond  to the Black  and  Veatch  categories — the plant was
discarded from consideration  and another random sample substi-
tuted. The  nine plant types, coded as numbers  1 through 9  in
Column 2 of Exhibit  13, are as indicated in Exhibit  14. Plants below
.5 MGD design flow are indicated by an asterisk in this column.

Next the  design size  for each sample plant was  extracted from the
STORET data and rounded to the nearest of 1, 3, 5, 10, 20, 35, 65,
80, or 100 million gallons per day in order to gain compatibility with
the plant-size categories  established in the Black and Veatch study.
Plant design capacities as  rounded  for the 50  randomly  selected
plants are shown in Column 3 of Exhibit 13.

The   operator  complement for  each  sample plant — Exhibit  13,
Column 4 — was determined on the basis of the Black  and Veatch
study, which sets forth standard plant manning tables for estimated
staffing needs developed  in that study for operators  (and other plant
personnel) according to plant  type (nine  categories)  and  design
capacity. While actual staffing in a given plant may not meet these
estimated needs, this study  presents  the best  available  basis for
determining complement. Because many operating plants are widely
reported to be staffed below recommended levels, it is likely that our
staffing estimates understate capital investment.

Further, we  suspect  that the  Black  and  Veatch  data  overstate
operators  because  they lack discretion for plants below the design
flow  of 1.0  MGD. Over 60  percent of the random samples were
plants with design flow of less than .5 MGD. Such plants are likely to
have  one  or  two  operators, often part-time.  While the Black and
Veatch  minimum  for its  1  MGD category  is  four operators for
primary plants and five for secondary, field research indicates that
the new smaller plants are often self contained and automatically
controlled — requiring little attention —  and that the older plants,
though needing additional workers to become effective, do not have
                               52

-------
                   EXHIBIT 13
   CALCULATED CAPITAL INVESTMENT PER OPERATOR
         FOR SO RANDOMLY SELECTED PLANTS

1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
14.
IS.
16.
17.
18.
19.
20.
21.
22.
23.
24.
25.
(1)
Plant Name
Seabrook
Itasca
Stamford
Chile
Lewisville
Monahans
Alpine
Mineral Wells
Universal City
Bellville
Lackland City
Galveston County No. I
El Paso (Ascarate)
Houston WCID No. 44- Plant
No. 2
Bexar County (Kiiby)
Columbus
Sour Lake
Houston Chadwick Manor
Granger
Waxahachie
Byers
Midland
Bexar County (Oak Hills)
Houston WCID No. 78 (Alief)
Sinton
(2)
Type
4
1
4
7
4
4
1
4
7
4
4
4
4
4
7
4
7
4
4
4
7
4
7
4
4
<3)
Sin
1
ซ
•
*
1
1
*
1
1
*
*
1
*
*
*
1
•
*
1
1
•
5
*
ป
1
<ซ>
Number of
Opinion
5
1
1
1
5
5
1
5
5
1
1
5
1
1
1
5
1
1
5
5
1
7
1
1
S
(5)
Population
Served
5,000
1,200
5,400
8,000
3,300
11,000
5,400
33,000
15,000
2,000
6300
5,300
2,500
4,700
2,300
3,500
1,600
500
1,300
11,800
500
61,700
6,300
2,000
4,800
(ซ)
Estimated Capital
Investment (ECI)
S 150,000
54,000
163,200
200,000
115,500
220,000
162,000
528,000
300,000
90,000
189,000
159,000
112,500
164.500
103,500
122,500
72,000
57,500
58,500
236.000
57,500
678,700
189,000
90,000
168.000
(7)
ECI per
Operator
S 30,000
54,000
163,000
200,000
23,100
44.000
162,000
10,560
60,000
90,000
189,000
31,800
112,500
164,500
103,500
122,500
72,000
57,500
11,700
47.200
57.500
96,957
189,000
90.000
33.600
"Under .5 MOD.
                       53

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                   EXHIBIT 13 (Cont'd)

26.
27.
28.
29.
30.
31.
32.
33.
34.
35.
36.
37.
38.
39.
40.
41.
42.
43.
44.
45.
46.
47.
48.
49.
50.

(1)
PbmtName
Silverton (Plaza Lake)
Eastland
Graham
Post
Van
Beeville (New Plant)
Port Arthur (El Vista WCID No. 1 1 1 )
Colorado City
Fort Bend County (Stafford)
Humble
Kemp
Kemah
Pasadena (North Side)
Alia Loma (WCID No. 8)
Arp
Lorenzo
Sugarland (Quarters Plan)
Lancaster
Graver (Farwell Draw)
San Diego (Stp Outfall 1)
Pinehurst
Wortham (Northeast)
EUchart
El Campo (Plant No. 1 )
Mabank
TOTAL
(2)
Type
1
4
4
1
4
4
4
4
7
4
4
4
4
4
4
1
4
4
I
4
7
1
4
4
1

(3)
Size
*
•
1
•
*
1
*
1
*
*
1
*
5
•
*
*
*
ซ
*
•
1
*
•
1
*

(4)
Number of
Operators
1
1
5
1
1
5
1
5
I
1
5
1
7
1
1
1
1
1
1
1
5
1
1
5
1
126
(S)
Population
Served
1,050
3,000
9,400
4,430
1,700
6.000
1,200
6,700
3,000
1,700
950
3,000
225,000
1,400
700
1,300
700
5,500
1,000
3,000
1,800
1,100
1,000
8,760
1,150

(6)
Estimated Capital
Investment (ECI)
47,250
105.000
235,000
155.050
76,500
180,000
54,000
201.000
105,000
76,500
80,750
105,000
1,125.000
63,000
59,500
58,500
59,500
165,000
85,000
105.000
81.000
49,500
85,000
219,000
51,750
S8.068.200
(7)
ECI PER
Operator
47.250
105,000
47,000
155,050
76,500
36,000
54,000
40,200
105,000
76,500
16,150
105,000
160,714
63,000
59,500
58,500
59,500
165,000
85,000
105,000
16,200
49,500
85,000
43,800
51,700
$ 64,033
"Under .5 MGD.
                          54

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l/l
I/I
                                         EXHIBIT 14

                                   SUMMARY OF BLACK AND

                               VEATCH PLANT TYPE CATEGORIES
Type
1
2
3
4
5
6
7
8
9
Liquid Treatment
Primary
X
X
X
X
X
X
X
X
X
Trickling
Filter



X
X
X



Activated
Sludge






X
X
X
Sludge Handling Facilities
Digestion
and Beds
or Lagoons
X


X


X


Digestion
and Sludge
Dewatering

X


X


X

Dewatering
and
Incineration


X


X


X

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sufficient  staff.  Accordingly, for  all sample  plants of  a design
capacity under .5 MGD,  we have  imputed a complement of one
operator.

Estimated capital investment per plant (Column 6 of Exhibit 13) was
calculated on the basis of population served by each plant and Texas
cost data developed under the Construction Grants Program (Public
Law 660) for fiscal year 1969. Population served by each sample
plant (Column 5) was derived from STORET system information in
most cases. Investment costs  were derived from the graph shown in
Exhibit 15,  which  charts  population  served  against  per capita
investment costs experienced under the Construction Grants Program
for secondary treatment  plants, excluding land costs. Estimated
capital investment per plant (Column 6) was calculated by multiply-
ing  the Column 5 population data by the  per  capita  cost  of
investment derived  from  Exhibit  15. Because our random sample
includes a few primary plants, capital investment estimates for those
plants may be slightly overstated.

The estimated capital investment (ECI) for each plant (Column 6 of
Exhibit 13)  was divided by the  calculated  number of operators
(Column 4) to derive the estimated capital investment per operator
(Column 7) for each of the 50 randomly selected plants.

Overall, in the 50-plant sample, there was a total estimated capital
investment of $8,068,200 under the responsibility of an estimated
126 operators, for an ECI per operator of $64,033. This investment
per operator is  substantially higher than the $10,200 invested by
American industry for each of its production workers.

     2.   Interpretation of Calculations

These  conservative  figures reveal  the minimum extent to which
public  investment in wastewater treatment facilities is exposed  to
risk when plant operation  and  maintenance  is entrusted to  an
untrained  or inadequately trained  operator. The real extent of the
risk accepted may be better appreciated when it is understood that
the ECI per operator offered above is calculated on the theory that
all operators are working at  the same time (that is,  that all of the
plants in the sample conduct single-shift operations). Although no
data are available  to indicate  the  dispersion  of operators among
shifts,  common  sense  and  casual  observation are  sufficient  to
conclude that some plants have operators on two or even three shifts.
If the  calculation were made on  the basis that to run two  shifts
necessitated an even split of operators between shifts, the average
value of plant entrusted to each operator at any one time would  be
                              56

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                        EXHIBIT 15
      PER CAPITA WASTEWATER TREATMENT PLANT
                 INVESTMENT COST DATA
    80


    75


    70


    65


    60


    55


    501
 n
 •o
 g  45
 w
 O
 ซ  40
    30

    25

    20 J

    15

    10

     5

     0
. o n. r>
          10   20   30   40  50  60  70   80   90   100  UO   120
           Sewage  Treatment  Plant Cost per Capita,  dollars
Source:   "Regional  Sewerage  Systems  and Treatment  Costs  in
         Texas," Nicholas W. Classen, Bobby G. Scalf, and Joseph
         B.  Copeland,  Jr., Texas  Water  Quality Board, Austin,
         Texas, Agency Publication No. 70-03.
                              57

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closer to $ 128,000. Further, as explained above, the use of Black and
Veatch  recommended staffing levels for this calculation renders the
number of operators somewhat high, thus resulting in a substantial
understatement of the average investment per operator.

Perhaps more important than the average is that many operators  in
Texas — and  presumably  elsewhere — are daily entrusted  with  as
much as $200,000 worth of plant and some with even more.  In
analogy, few  drivers  would entrust a $3,000 automobile  to  an
untrained, inadequately trained, or unlicensed driver, and  a  waste-
water treatment plant operator is daily responsible for over 20 times
this investment.

In contrast to the ECI per operator, which may well range  in excess
of the  $64,033  presented in Exhibit  13, EPA experience  in the
Public Services Careers  Program and other similar operator training
programs suggests  that the cost  of  training a single operator,
exclusive of support costs associated with training of the disadvan-
taged, average in the vicinity of $565.

B.   Wasted Investment Through Substandard Effluent

Another perspective on the value of training benefits was developed
through further consideration  of some of the plants  which were
subjects of the Part IV case studies to determine the extent  to which
training prevented waste of capital investment that would have been
caused by delivery of a substandard product. In a number of the case
studies,  plants were identified in which recent  training could be
isolated  as  the  substantial cause of  improved performance. For
certain  of these improvement cases, quantitative data showing the
quality  of the effluent  in  terms of BOD and TSS before and after
training were available through the Texas Water Quality Board. These
data were manipulated as described below to calculate the  "stop-
loss" on capital investment. A further calculation offset the cost  of
training against the stop-loss on capital to estimate the net return on
the training investment for these plants.

     1.    Explanation of Calculations

The  plants selected for inclusion in this portion of the study include
the four plants cited in Operation Cleansweep in the first quarter of
1971  for  noncompliance  with WQB  standards that could  be
identified as achieving performance improvement largely as a result
of training.  In addition,  15 plants identified by the Texas WQB
district  supervisors as having improved their performance as a result
                               58

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of training since 1970 were included because data were available. For
all  19  of these case study plants, data to substantiate the perfor-
mance  improvement were derived  from the Texas Water Quality
Board  self-reporting information system. Data on the 19 plants are
presented in Exhibit 16.

Effective improvement in performance (Column 2) was calculated on
an  average basis, giving equal weight to BOD and  TSS levels. The
figures  presented  in  Column 2  of Exhibit  16 were  derived by
calculating the difference between first-quarter and last-quarter 1971
levels of BOD and TSS and averaging them.

Column 3 sets  forth an average of the BOD and TSS performance
standards established  for  each plant by the Texas Water Quality
Board.

The capital investment figures presented for each plant in Column 4
were calculated on the basis of population  served by each plant and
Texas  cost data developed under the Construction Grants  Program
for fiscal year  1969,  as  described in  the calculation of  ECI per
operator in Section  A-l  above.  Supporting data  are provided in
Appendix A.

The effectiveness with which the capital investment for each of these
plants  was being utilized  before and after training was expressed in
terms of the imputed proportion of the investment that was actively
producing  to  design  capacity.  Pre-training effective capital was
calculated by  dividing the standard for each plant by the average
combined BOD/TSS performance before training (in the first quarter
of  1971);  the  quotient, representing  the  fraction  of  intended
BOD/TSS removal being realized before training, was multiplied by
the plant's total capital investment to determine the equivalent fully
effective capital investment that would produce the same quality
effluent. In  some instances, plants that were performing well within
their compliance  specifications  have  pre-training  effective  capital
estimates well in excess of their actual capital investment costs. This
implies that the plants were already performing more effectively than
was hoped.

Post-training effective capital was calculated by dividing the standard
for each plant by its average combined  BOD/TSS performance after
training (in  the last quarter of 1971); the quotient representing the
fraction of plant effectiveness after training was again multiplied by
the total capital investment in the plant to determine the equivalent
effective capital represented by  its performance.  Pre-training and
                               59

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                    EXHIBIT 16
  CALCULATION OF "STOP-LOSS" ON CAPITAL INVESTMENT
AND RETURN ON TRAINING INVESTMENT IN 19 CASE STUDIES
(I)
Plant
Kaufman
Corpus Christ! (WSIde)
Corpus Christi (B'Way)
Mathis
Lockhart
Jasper
ป Beaumont
Brownwood
Midland
Odessa (BOD only)
Grandview
Forney
Piano
Nocona
Bridgeport
Gainesville
Brownsville
Donna
Edirftmrg
TOTAL
AVERAGE
(2)
Average
Effective
Change
38.5
14.0
3,8
23.2
9.5
4.6
5.9
30.5
5.9
178.8
6.5
10.2
4.0
32.0
16.0
6.7
12.7
25.2
4.4
(3)
Avenge
BOD/TSS
Standard
34.5
20.0
20.0
57.0
20.0
103.0
20.0
23.0
20.0
35.0
20.0
20.0
20.0
77.0
30.0
20.0
20.0
20.0
20.0
(4)
Capital
Investment
164,500
175,000
400,000
174,000
207,000
150,000
544,000
342,000
678,700
795,300
85,000
78,750
260,000
153,125
140,000
300,000
643,000
198,000
360,000
5,848,375
307,809
(5)
Pre-Trainlng
Effective
Capital
85,540
98,000
240,000
140,940
298,080
364,500
451,520
430,920
1,174,151
508,992
115,600
96,075
239,200
208,250
128,200
232,500
482,400
39,600
288,000
5,622,468
295,919
(6)
Post-Training
Effective
Capital
205,625
164,500
272,000
210,540
910,800
408,000
598,400
639,540
2,395,811
1,725,801
207,400
255,938
293,800
482,343
257,600
312,000
926,208
87,120
348,480
10.701,906
563,258
(7)
Stop-Lois
on Capital
120,085
55,500
32,000
69,600
612,720
43,500
146,880
208,620
1,221,660
1,216,809
91,800
159,863
54,600
174,093
129,400
79,500
443,808
47,520
60,480
4,968,438
261,497
(8)
Costal
Training
2,825
3,955
4,520
2,825
2,825
3,390
3,390
2,825
3,955
5,085
565
565
3,955
565
565
2,825
3,955
2,825
2,825
53.675
2,825
(ป)
Net
Return
117,260
62,545
27,480
66,775
609,895
40,110
143,490
205,795
1,217,705
1,211,724
91.235
159,298
50,645
173,528
128,835
76,675
439,853
44,695
57,655
4,926,763
259,303
(10)
Ratio of
Training
Investment:
Net Return
1:42
1:15
1:6
1:24
1:216
1:12
1:42
1:73
1:307
1:238
1:161
1:282
1:13
1:307
1:228
1:27
1:111
1:16
1:20
1:91
00
%
Improvement
After
Training
240
166
112
149
316
112
132
148
204
334
178
266
122
231
198
135
191
155
121
(12)
%
Reduction of
BOD/TSS
in Effluent
58
40
11
65
68
11
24
32
51
65
44
62
18
57
49
26
48
36
17

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post-training effective capital estimates appear in Columns 5 and 6,
respectively, of Exhibit 16.  "Stop-loss"  on capital (Column 7) was
derived by subtracting Column 5 from Column 6.

The number of operators in each plant was estimated according to
Black and Veatch staffing guides and EPA STORET data regarding
type and size of plants, as described in section A-l, above. Since the
actual proportion of the operator staff trained in  each case was
unknown, it  was assumed  that all  operators in each plant  were
trained;  clearly  this  method overstates the  number of  trained
operators. The number  of  operators for each plant was  then
multiplied by $565, the cumulative historic cost experience of EPA
in administering the Public  Service Careers Program  for operator
training (exclusive of the expense of supportive services offered to
disadvantaged  trainees).  Resulting  training cost calculations are
shown in Column 8.

Net gain in effective capital, shown in Column 9,  was derived by
subtracting Column  7 from  Column 8. The Column  10 ratio of
training investment to net capital return was calculated by dividing
Column 9 by Column 8.

Percentage improvement in plant performance in terms of increase in
BOD  and TSS  removal was determined  by  dividing BOD/TSS
combined average performance in the first  quarter of 1971  by the
level of performance achieved after training, in the last quarter of
1971. The results of this procedure are presented in Column 11 of
Exhibit  16.

Finally, the percentage of the reduction of BOD/TSS in the effluent
of each of these plants was determined by dividing  the effective
change (Column 2)  by the  BOD/TSS performance  achieved before
training (in the first quarter of 1971).

     2.   Interpretation of Calculations

As shown in Exhibit 16, the net improvement in effective capital in
the 19 case-study plants was equivalent to a combined investment of
$4,926,763. For every dollar invested in training in these plants, the
equivalent of an additional $91 investment was activated in terms of
improved performance. As a result of training, the quality of effluent
produced by  all of these plants improved substantially, in a range
from  11 to  68 percent reduction of average combined BOD/TSS.
Further, overall improvement ranged between 112 and 334 percent
over pre-training levels.
                              61

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These results are sufficiently startling to warrant further comment, in
terms of both the reliability of the calculations and  their implica-
tions.

It  is recognized that the data utilized to produce the calculations
displayed in Exhibit  16 are less  than perfect  and could have been
improved substantially upon  additional research  conducted over a
longer period and with more resources than were available for this
study. In addition,  the availability of additional data would have
permitted refinement of the calculation methodology and might have
permitted consideration of operation and maintenance  costs.  The
limited qualitative data we have  indicates that both operation and
maintenance costs  are likely to  rise after training because trained
operators command higher wages  and are likely  to  perform vital
routine maintenance tasks that  were previously  ignored. Further,
consideration might well have been given to the value of the possible
extended plant life  that could result  from improved operator
maintenance procedures as a result of training.

A  further qualification is found  in  the methodology. The final
calculations represent a measure of stop-loss on capital and return on
training investment over the life  of plants only if it is assumed that
the plants had always, before training, been operating at the level of
effectiveness measured just prior  to training (during the first quarter
of 1971) and that  they will continue, after training,  to perform at
least  as  well as the level achieved just before training  (in the last
quarter of 1971). Obviously performance in the past and future may
vary with a  variety of independent phenomena, such as quantity and
quality of influent, plant age, and so forth.

Nevertheless, we believe that the calculations presented in Exhibit 16
do offer a reasonable benchmark of the value that can be attributed
to investment in wastewater treatment plant operator training. If
these figures overstate the value of training investment  by as much as
50  percent, the conclusion that the payoff  an operator training
investment is enormous remains valid.

On the basis of this study, it is not possible to state with certainty
that the training investment results that are presented in this  report
may be imputed to operator training in general throughout the state
of Texas and throughout the country. The fact that in 12 of the 16
plants called before  Operation Cleansweep in the first quarter of
1971,  training had no apparent influence on subsequent performance
improvement does not say that trained operators were not  essential
to effective  operation in those plants. It does say that without  regard
                               62

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to the status of operator training in those plants, other adjust-
ments in plant, equipment, staffing, or funding were necessary
before improved operating efficiency would be possible. We can
accept as fact that in many plants—and probably most plants—
training acts in combination with other factors to cause effective
performance. Yet the fact that a number of cases were found in
Texas in which training could be identified as the only significant
variable leading to effective performance signifies that training is
by itself, as  well  as in combination with other factors, critical to
realization of anticipated return on capital investment.

Thus far, we have  been examining overall  return on training
investment without reference to the different views of investment
and return as they might appear at different levels of the govern-
ment. Typically the largest share of the capital for investment in a
treatment plant comes from the federal and  state governments.
On the  other hand, local governments bear almost  the entire
operation and maintenance costs. If, as we suspect, the cost of
operation and routine maintenance goes up with training, local
decision-makers might see a negative incentive to invest in train-
ing.  This might be true particularly if  the local government
must pay for all or  part of  the training.

However, in Texas, as in some other states,  there is a very real
potential out-of-pocket cost to the local government if its plant
effluent is not meeting the state standard. This is a daily fine to be
paid to the state for noncompliance; in Texas, it is $1,000 a day
for each day of  noncompliance. These fines are imposed only
after exhaustive efforts have been made by the WQB, and where
there is utter disregard for the Board's recommendations. While
plant effectiveness  varies and generally noncompliant plants
may be in compliance on some days,  the fine can obviously add
up rapidly and become a very substantial sum. Particularly for
smaller  communities, such  a fine would seem  to provide an
incentive for communities to train operators if this is the action
required to reach compliance.

In 17 of our sample cases in Part IV, plants  moved from a gen-
erally noncompliant to a compliant status substantially as a result
of operator training. Bringing a plant into compliance represents
a very real  return  on training investment in the fear of fines
avoided for  these localities. However, because the fine is a pay-
ment from  one  government body to another—a transfer of
money from one jurisdiction to another encompassing jurisdic-
tion—it is not a real saving to the national or even  statewide
public. Therefore, we have not calculated this as a part of the
national  return on training.
                            63

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C.  • Conclusions Regarding the Return on the Public Investment in
     Wastewater Treatment Plant Operator Training

The average  estimated capital investment per operator is at least
$63,700 and  could well be  closer to  $127,400.  Further, many
individual operators in Texas — and presumably elsewhere — daily
hold responsibility for capital  plant valued at $200,000 or more. All
of these figures are considerably higher than the $10,200 invested on
the average by American industry for each of its production workers
and support the need  for training as insurance that capital will be
used optimally.

An analysis of 19 of the case-study plants discussed in Part IV of this
report  revealed that  for  every  dollar  invested  in  training, the
equivalent  of an additional  $91  investment  in  capital plant was
activated in terms of improved performance. Further, the degrees of
reduction of BOD/TSS in  plant  effluent and  levels  of overall
improvement following training indicate conclusively that for these
plants, the value of the return on training was high hi terms of both
dollar investment and cleanliness of water treated.
                               64

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                     APPENDIX A
  ECI PER OPERATOR CALCULATIONS FOR 19 CASE STUDIES

1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
14.
15.
16.
17.
18.
19.
0)
PbntName
Kaufman
Corpus Christi(WSide)
Corpus Christi (B'Way)
Mathis
Lockhart
Jasper
Beaumont
Brownwood
Midland
Odessa
Grand view
Forney
Piano
Nocona (South)
Bridgeport
Gainesville
Brownsville
Donna
Edinburg
O)
TVpe
4
4
5
4
4
1
4
4
4
7
7
4
4
7
1
4
4
4
4
(3)
Size
1
3
10
1
1
3
3
1
5
5
*
*
5
*
*
1
5
1
1
(4)
Number of
Operators
5
7
8
5
5
6
6
5
7
9
1
1
7
1
1
5
7
5
5
(5)
Population
Served
4,700
5,000
82,000
5,800
6,900
5,000
34,000
18,000
61,700
72,300
1,000
1,750
13,000
4,375
3,000
15,000
53,600
6,600
20,000
0ป
Estimated Capital
Investment (ECI)
164,500
175,000
400,000
174,000
207,000
150,000
544,000
342,000
678,700
795,300
85,000
78,750
260,000
153,125
140,000
300,000
643,200
198,000
360,000
(7)
ECI
Per Operator
32,900
25,000
50,000
34,800
41,400
25,000
90,666
68,400
96,957
88,367
85,000
78,750
37,142
153,125
140,000
60,000
91,886
39,600
72,000
•Under .5 MGD
                       65

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                    ACKNOWLEDGMENTS
Harbridge House wishes to acknowledge the assistance of the Texas
Water Quality Board  (WQB)  in permitting this investigation to be
made and materially assisting  in its execution. The WQB generously
provided most of the data  on the case examples and the statistical
studies from their extensive and well-organized files and reports. Also
to be thanked is the Water Resources section of the North Central
Texas  Council  of Governments  (NCTCOG)  whose  personnel
materially helped in data collection and served as a sounding board
for some of our findings.

Despite  the generous  assistance of these two  organizations, the
findings,  conclusions, and recommendations presented in this report
remain the responsibility of Harbridge House.
                              67

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