Your Wastewater Is My Drinking Water; My Wastewater Is Your Drinking Water


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Your Wastewater is My Drinking Water; My Wastewater is Your Drinking Water: The importance of cross jurisdictional standards for operator training and certification as it affects the quality of coastal waters, inland seas, and rivers.

Carla Sydney Stone

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Your Wastewater Is My Drinking Water; My Wastewater Is Your Drinking Water

  1. 1. Speech to Black Sea Water Quality Conference Your Wastewater is My Drinking Water; My Wastewater is Your Drinking Water: The importance of cross jurisdictional standards for operator training and certification as it affects the quality of coastal waters, inland seas, and rivers. Carla Sydney Stone Delaware Technical & Community College* People living along the Black Sea drink, bathe and swim in wastewater discharges. It is not a pretty picture. Some countries are more successful in controlling pollution than others; yet, their border waters are degraded, not because their own industries and utilities operate at substandard levels, but because their neighbors‟ do. The Black Sea is one of the world‟s most complex and isolated inland seas. It receives the drainage from a 420,000 square kilometer basin, covering about one third of the area of continental Europe, including areas from seventeen countries, and Europe‟s second, third, and fourth rivers.1 The Black Sea Strategic Action Plan states: “The state of the Black Sea environment continues to be a matter of concern due to the ongoing degradation of its ecosystem and the unsustainable use of its natural resources”2 This multilateral plan is a mechanism for ensuring that each country in the Black Sea region is a partner, not a polluter. The overall aim of the Plan is to: “enable the population of the Black Sea region to enjoy a healthy living environment in both urban and rural areas, and to attain a biologically diverse Black Sea ecosystem with viable natural populations of higher organisms, including marine mammals and sturgeons, and which will support livelihoods based on sustainable activities such as fishing, aquaculture and tourism in all Black Sea countries”.3 In Europe, the EU Water Framework Directive 4 requires that within fifteen years of adoption, Member States must achieve water quality objectives. For example, the river basin management plan requires that all countries: 1 Mee, Laurence, D., How to Save the Black Sea, Your Guide to the Black Sea Strategic Action Plan, 2 Strategic Action Plan for the Rehabilitation and Protection of the BlackSea, 3 Strategic Action Plan for the Rehabilitation and Protection of the BlackSea, 4 Directive 2000/60/EC of the European Parliament and of the Council of 23 October 2000, establishing a framework for Community action in the field of water policy [Official Journal I. 327,22.12.2001] Amended by Decision No. 2455/2001/EC of 002b.htm European Parliament and Council, of 20 November 2001 [Official Journal I. 331, 15.12.2001].
  2. 2. “prevent deterioration, enhance and restore bodies of surface water, achieve good chemical and ecological status of such water and reduce pollution from discharges and emissions of hazardous substances; protect, enhance and restore all bodies of groundwater, prevent the pollution and deterioration of groundwater, and ensure a balance between astraction and recharge of groundwater; preserve protected area.”5 The EU Directive does not specify the exact means by which individual countries are to comply with the Directive. However, when many countries share water resources, those countries that do not pursue compliance with the Directive, block the ability of those countries that do. The need for consistent policy and cooperation among nations is emphasized by the European Union of National Associations of Water Suppliers and Waste Water Services in its statement, Our Vision for the Future. “…the main goal of guaranteeing the customers safe and clean water supplies and an efficient waste water system at an affordable cost…” must include the following key elements: “A SKILLED WORK FORCE Highly skilled and motivated staff are the key to high quality water services. Their training and development will remain crucially important. STANDARDIZATION The development of suitable product and system standards underpins the provision of safe, reliable water and waste water services. PROMOTION OF SUSTAINABLE DEVELOPMENT European legislation should promote the sustainable development of water resources through the effective management of water. CONSUMER/POLLUTER PAYS PRINCIPLE It is essential to achieve proper implementation of the polluter pays principle and fair allocation of costs among the different sectors involved: domestic consumers, industry and agriculture.”6 The challenges confronting countries surrounding the Black Sea are more complex than those of EU Member States and EU Accession and Pre-Accession countries. Primarily this is because their economic and political systems are so diverse, and the sad legacy of environmental neglect is so great. Large areas of these countries are in need of ecological amelioration. Old methods will not work. New thinking is required. The Black Sea Strategic Action Plan and the April 1992 Convention for the Protection of the Black Sea against Pollution (known as the Bucharest Convention, because it was signed in Bucharest) provide a basis for countries in the region to work together to develop an entirely 5 6 European Union of National Associations of Water Suppliers and Waste Water Services, Our Vision for the Future,
  3. 3. different approach to meeting environmental quality standards. The Bucharest Convention and the Strategic Plan provide a mechanism whereby countries can develop and implement pollution control legislation and regulations without regard to national boundaries. Black Sea countries can establish international mandatory training and certification requirements for water and wastewater operators. Using the US Model Black Sea region countries‟ legislative and regulatory environments are clearly different than those in the United States of America. However, much can be learned from examining the US experience in providing a regulatory framework for the environments of individual states. Each American state can be thought of as representing a country within the Black Sea region for the purposes of this discussion. In particular, the Black Sea Region can be compared to the Chesapeake Bay Region within the US. Actions within the borders of one state affect the environment of another. Discharges from one state into a river may affect the quality of water into an estuary downstream in another state. The United States is governed through both a Federal and State legislative and regulatory system. In the case of environmental laws, the Federal Government mandates that the states meet environmental standards, yet often lets the individual states decide the best way to implement the Federal regulations within the state boundaries. The US Environmental Protection Agency Environmental Training Assistance Program and the US Clean Water Act both provide models for providing the mechanisms for Black Sea countries to require operator training. Operator Training Legislation and Regulations The federal Clean Water Act requires that all treatment facilities be operated by personnel specifically trained for that responsibility. All 50 states require that all wastewater operators be properly certified. Each state has specific eligibility requirements that must be met by prospective operators prior to making an application for an operator certificate or license. All states require an operator to pass an operator‟s certification examination. The federal Safe Drinking Water Act requires that all operators be trained and certified. In order to maintain the operator license, annual continuing education is required in most states for wastewater operators, but mandated for water operators under the federal Safe Drinking Water Act. Why Legislate Training Provisions? Regulations perform five important functions. THEY PROVIDE CONSISTENCY IN FACE OF POLITICAL AND ECONOMIC CHANGE - This protects operators and the public from political pressure. This is
  4. 4. especially important during times of economic straits when it can be tempting to cut costs, even if doing so would result in a risk to public health. REGULATIONS REQUIRE COMPLIANCE AND PENALIZE NON-COMPLIANCE Penalties such as fines or loss of operating permits are power incentives for compliance with environmental regulations. REGULATIONS GIVE DIRECTION TO THE INDUSTRY - They construct a framework within which managers, operators and those who provide training may function. STANDARDIZED PROTOCOLS ASSURE THAT ALL PLANTS OPERATE AT THE SAME STANDARD OF CARE – Plants located in different jurisdictions are required to follow the same practices. REGULATIONS SET PERSONNEL COMPETENCY STANDARDS - Clear, measurable operator or plant competency standards allow little room for error The Clean Water Act The United States Environmental Protection Agency (EPA) Clean Water Act requires that competent personnel are provided to operate wastewater treatment facilities. Additional legislation (40 CFR Part 45) sets standards and protocols for the provision of training under the Clean Water Act. Inclusion of training requirements in US environmental regulation attests to the level of importance of a properly trained work force in the proper operation of environmental protection facilities. The Clean Water Act requires and supports training in three sections: Section 1254, Section 1259 and Section 1261. Under Section 1254, the administrator of the United States Environmental Protection Agency (similar to a Cabinet Minister in Black Sea countries) is authorized to provide support for research, investigations, training, and information for the proper operation of treatment facilities. Section 1259 authorizes the award of training grants and contracts to institutions that provide operations personnel training. EPA provides funding for the planning and for the development or expansion of training programs or projects; training and retraining of faculty members; conducting short-term or regular training sessions; research necessary for the development of training methods, the preparation of teaching materials and the planning of curriculum. These funds are important to Environmental Training Centers such as that at Delaware Technical & Community College. Under Section 1261, EPA‟s Administrator is authorized to award scholarships for undergraduate study by persons who plan to enter an occupation involving the operation and maintenance of treatment works. The Administrator allocates scholarships among institutions of higher education with
  5. 5. approved wastewater technology education programs. These scholarships provide operators and students who aspire to greater levels of achievement and professionalism within the industry the means to do so. These same scholarships also are important funding sources to the institutions that provide training and education. Environmental Training Commitment While Section 1254 outlines the purpose of providing an adequate supply of trained personnel, 40 CFR Part 45 provides the support mechanism for training: the Environmental Training Assistance Program. The Environmental Training Assistance Program provides funding to institutions, most of which are State sponsored environmental training centers such as the Environmental Training Center at Delaware Technical & Community College. The United States government through the Environmental Protection Agency provides funds for training facility infrastructure, training personnel, training peripherals, and operator scholarship funding. There are many environmental training centers throughout the U.S. functioning with various degrees of success. The Environmental Training Center at Delaware Technical and Community College is a successful training center that is funded through the Clean Water Act regulation. Operator Competency Assessment If training is required by regulation, then there must be a method to assess its success. In the United States, there are two ways to measure success. 1. Operator Certification provides a means of evaluating the technical competency of the operational personnel. 2. Facility Compliance provides a measure of overall evaluation of the performance of facilities where trained operators are employed. Operator Certification Program This program is administered at the state level in all 50 states via appointed State of Boards of Certification. For example, the Delaware Department of Natural Resources and Environmental Control, administers the certification program in Delaware. Canada operates a similar program at the Provincial level. Under operator certification requirements, potential operators must take and pass written examinations demonstrating technical competency. These tests provide an objective assessment of the effectiveness of training programs utilized by the operators. A satisfactory performance on the examination earns the operator a license certifying his /her competency. Only licensed operators are permitted to make facility operational decisions. This is just the beginning of the operator‟s training and measurement of competence. Operators are required to attend periodic continuing
  6. 6. education training to maintain their certification/license. State regulations specify the numbers of hours and types of training operators must complete in order to maintain their license. Advanced skill training is made available through programs such as those provided by Delaware Tech which offer career track advancement through advanced certification levels. Delaware Tech has trained every operator in Delaware and has an outreach program to train operators in neighboring states. As operators climb the ladder of certification levels, they assume more responsibility for the plant‟s operations. Benefits of a Trained Workforce There are many benefits of trained workforce in water or wastewater facility. Operations personnel who understand the technology involved throughout a facility will perform their work confidently and with a higher degree of competency. Certified career operators with a career path in an industry are more committed to the job. Most importantly, trained personnel are better able to recognize changing conditions, take corrective action, and reduce non-compliance and the possibility of fines. Facility Benefits The water or wastewater facility benefits from trained personnel. For example, properly operated and maintained equipment suffers less downtime for repair, saving money. Properly operated and maintained equipment has a longer operational longevity. It does not need to be replaced as often, saving money. Finally, trained personnel reduce non-compliance frequency and thus reduce potential fines, saving money. Since all states are required to provide operator training and certification, there is no incentive for any one state to pollute. Indeed, states compete to be thought of as the most “environmentally friendly” state in a region. Cross Jurisdictional Boundaries – The Chesapeake Bay Watershed The Chesapeake Bay is an inland body of water located in the Mid-Atlantic States (Environmental Protection Agency Region 3) of the United States. Waters flow into the Chesapeake from New York, Pennsylvania, Maryland, Delaware, Virginia, and West Virginia, among others. Some of the waters flowing into the Chesapeake include the Susquehanna, Rappahannock, Potomac, James, Delaware, Choptank, Nanticoke and Patapsco Rivers. Major cities in these states include Washington, D.C., Annapolis, MD., Baltimore, MD., Richmond, VA, Alexandria, VA, and Harrisburg, PA. Industries in these states include steel and coal, agriculture, poultry, shipping, transportation, petroleum refining, automakers, chemicals, and manufacturing, fishing, especially shellfish, and tourism. These industries mirror the economic activities of Black Sea region countries. In 1993, the Executive Board of the Water Environment Federation (WEF) examined the issue of certification of wastewater operators and came to the conclusion
  7. 7. that certification is “best managed at the state level”. WEF advocates “…continuation and strengthening of existing state certification programs”7. However, the WEF also found that states presented widely varying certification requirements, not all of which reflected the complex reality of environmental laws and regulations and the level of technology needed to meet these standards. Therefore, the WEF Board approved the position that the United States should adopt: “…a set of minimum national certification criteria which all wastewater operations personnel should meet. Uniform minimum criteria should be established on a national basis for states to utilize in their certification programs. National minimum criteria would enable each state to manage a certification program based on the collective knowledge and experience of treatment plant personnel from across the nation, while maintaining programs suited to the unique needs of individual states.”8 The Results Operator training and certification works. Delaware, one of the states in the Chesapeake Bay Watershed, was one of the last states to open an environmental training center – and it showed. The state had difficulty meeting the requirements of the federal Clean Water Act. Municipalities and industrial companies committed numerous violations of water discharge permits. A study conducted by Delaware‟s largest newspaper, The News Journal, uncovered 1,892 violations in the 18 months between January, 1994 and June 30, 1996.9 Delaware‟s Environmental Training Center offering wastewater operator training opened in 1996. By 1998, companies, and municipalities with discharge permits had reduced their violations by 90%. During this time period, only 172 violations were incurred. 10 Delaware has since held a three year record: no significant water or wastewater incidents – a perfect record. Here is proof that training works. Peter Hansen, state surface water discharge manager has said, “There is no question the environmental training center was a major contributor to this success.”11 However, Delaware‟s success in controlling pollution is for naught unless other states whose waters feed into the Chesapeake also control pollution. Discharges by municipal and industrial facilities located in other states will affect the condition of the Chesapeake through runoff into tributaries and rivers that feed into the Chesapeake Bay. Maryland, home to much of the Chesapeake Bay must meet Delaware‟s example. And it does. An examination of Maryland‟s Enforcement and Compliance Report for Fiscal 200312 shows that Maryland meets Delaware‟s standards. 7 “Wastewater Operations Certification and Training”, Approved April 13, 1993, by the WEF Executive Committee, WEF - Government Affairs - Policy - Wastewater Operations Certification and Training.htm 8 “Wastewater Operations Certification and Training”, Approved April 13, 1993, by the WEF Executive Committee, WEF - Government Affairs - Policy - Wastewater Operations Certification and Training.htm 9 Murray, Molly, “Waste discharge record improves”, The News Journal, October 4, 1999 10 Murray, Molly, „Water discharge record improves”, The News Journal, October 4, 1999 11 Murray, Molly, “New training program key to improving compliance, The News Journal,, 1999 12 Maryland Department of the Environment, Annual Enforcement and Compliance Report, Fiscal 2003
  8. 8. Maryland issues groundwater discharge permits to regulate the amount of water using spray irrigation or other treatment method. For the year, fiscal 2003, 100% (one hundred percent) of inspected facilities were in significant compliance.13 Not a single municipal or industrial had a significant violation. State and National Pollutant Discharge Elimination System (NPDES) permits are issued to any industrial, municipal, or agricultural user who discharges wastewater into surface waters, or from which storm water runoff emanates. These include municipalities, schools, commercial sewage treatment plants, industrial facilities or agricultural operations such as feeding operations. The year 2003 was an especially difficult year in Maryland. The Chesapeake region was hit directly by Hurricane Isabel in September, 2003 resulting in the discharge of tens of millions of gallons of raw sewage when sewage pumping stations and waste- water treatment stations flooded and lost electricity. "While you had millions of gallons of sewage, it's mixing with millions of gallons of extra water, so it is somewhat diluted," said Richard McIntire, a spokesman for the Maryland Department of the Environment.”14 However, as a precaution, the Maryland State Environmental officials also temporarily banned shellfish harvesting in Maryland's portion of the Chesapeake Bay and its tributaries, “saying the raw sewage released during flooding may have exposed shellfish to disease-causing organisms.”15 The weather did not stop at a single state‟s border; and Virginia officials also closed their portion of the bay to shellfish harvesting. However, plants soon returned to normal operation, ameliorating the storm‟s negative effects. Nowhere is the need for uniform, standard operator training requirements and regimens more apparent, than when examining the effect of pollution on environmental markers such as wildfowl. In a study conducted by U.S Geological Survey‟s Patuxent Wildlife Research Center, Barnett Rattner, a scientist who headed the study said that “Things certainly look a lot better than they did 20 years ago.”16 Scientists examined osprey nesting sites in four areas throughout the Bay region: Elizabeth River in Virginia, Anacostia River Washington D.C. and adjacent areas of the middle Potomac, Baltimore Harbor and the adjacent Patapsco River, and reference sites in the South, West and Rhode rivers in Maryland. Ospreys are particularly good indicators of environmental quality since pairs mate for life and return to the same site to nest each year. “Their population, once numbering in the thousands of pairs, plummeted by as much as 6 percent a year during the 1960s. By 1973, only 1,450 nesting pairs were reported around the Bay. Today, they have rebounded to more than 3,500 pairs Baywide.17 13 Maryland Department of the Environment, Annual Enforcement and Compliance Report, Fiscal 2003, p.116 14 Zaneski, Cyril T. ” Extent of storm damage growing”, Baltimore Sun, 23 September 2003, p.1. 15 Zaneski, Cyril T. ” Extent of storm damage growing”, Baltimore Sun, 23 September 2003, p.1. 16 Blankenship, Karl, “Ospreys Doing Better in the Bay Area, Although Concerns Linger”, Alliance for the Chesapeake Bay Journal, Volume 14, Number 2, April, 2004, 04/osprey.htm 17 Blankenship, Karl, “Ospreys Doing Better in the Bay Area, Although Concerns Linger”, Alliance for the Chesapeake Bay Journal, Volume 14, Number 2, April, 2004, 04/osprey.htm
  9. 9. What Can Black Sea Nations Do? A survey18 conducted by Delaware Technical & Community College showed that, by and large, companies offer no operator training. Only 6% of managers reported that their plants offer any type of training. However, an overwhelming majority of Bulgarian managers of water and wastewater treatment plants support mandatory operator training and certification. The support is so great that three quarters of the managers surveyed would use company funds to pay for operator training. Experience shows that operator certification requiring increased training results in decreased equipment downtime, fewer discharges, fewer regulatory infractions, or fines, less frequent equipment replacement, decreased costs and increased reliability of service. Operator certification also improves worker professionalism, pride, and creates opportunities for workers to advance in their chosen career. The Strategic Plan outlines an ambitious program for the regulation of point sources. Section 35 requires signatories to undertake action in the following areas: a) harmonization of water quality objectives based on water uses (drinking water, bathing water, aquaculture, ports etc. b) harmonization of procedures used for monitoring the actual discharge of effluent at point sources. c) Adoption and implementation in accordance with its own legal system, the laws and mechanisms required for regulating discharges from point sources using licensing and the polluter pays principle. d) Adoption and implementation in accordance with its own legal system, efficient enforcement mechanisms. e) Ensure that the national agencies responsible for licensing, monitoring and enforcement are adequately staffed and that the necessary resources are available to them. Where necessary, training courses at local agencies will be organized. f) Introduction of policies whereby polluter pays for compliance, including encouraging the use of environmentally friendly production processes or other innovative process which reduce inputs of pollutants. 19 The Black Sea Strategic Action Plan and the Convention for the Protection of the Black Sea against Pollution provide the appropriate framework allowing signatories to harmonize national policies and standards while maintaining control over specific legislation and regulations. The Global Environmental Facility, the World Bank, the European Union, US Agency for International Development, and other funding sources, are helping Black Sea nations to build new wastewater and water treatment facilities costing billions of dollars. However, most of these new plants will not be built before the Directive goes into effect. The most cost effective and environmentally effective approach to treatment plant operation, especially in the near future, is for Black Sea nations to require operator training and certification. It is important that Accession Countries, and those countries that aspire to Accession (most of the Black Sea Region) 18 Conducted 18 February 2004, Sofia, BG 19 Strategic Action Plan for the Rehabilitation and Protection of the Black Sea,
  10. 10. realize that the EU water directives will need to be met either through preventive measures now or by paying fines and punitive remediation costs later. . Who should provide the training? Non Government Organizations (NGOs) should give operator training, not the equipment vendors. Although equipment vendors do provide initial training, they provide training only for their particular equipment, not the total system. The NGOs, not bound by the constraints of commercial business, serve a larger constituency. They are able to provide training for a wide range of systems supplied by a variety of vendors. NGO training guarantees operator training program sustainability. As operators leave their jobs over the course of several years, either because of retirement or career changes, their replacements will need to be trained. Vendors may not be available to supply the training because their training contracts have expired; they have left the market; the equipment they are currently manufacturing does not match the original specifications of that sold some years before; or training does not provide enough, if any, income for the company. Operator training should never be subject to the vagaries of market conditions. By relying on NGOs such as Delaware Technical & Community College, state governments in America avoid the introduction of additional layers of bureaucracy. For example, in Delaware, only --- people are employed by the Department of Natural Resources and Conservation to oversea the training of ---thousand water and wastewater operators. In Maryland, the Department of Environment employs only ---- people to administer the training and certification of -----thousand water and wastewater operators. This results in significant taxpayer savings. In Bulgaria, the Bulgarian Water and Wastewater Operators Training Center, an NGO, will assume the responsibility for operator training. Conclusion The Black Sea nations have laid a strong foundation for improving the Black Sea. Under the Bucharest Convention and the Black Sea Strategic Action Plan as the international framework, each nation can and must develop water and wastewater operator training and certification. To do anything less will undermine the good work that has gone before. *This work has been supported by a cooperative agreement from the United States Agency for International Development.