Mr. William Hogan

Engineer of WPCF

Bureau of Water Management

Planning and Standards Division

State of Connecticut

Department of Environmental Protection

79 Elm Street

Hartford, CT 06106-5127

Re: Proposed Wastewater Laboratory Analysts Certification Program

Dear Mr. Hogan:

On behalf of the Board of Directors of the Connecticut Water Pollution Abatement Association (CWPAA) I present this position paper in reference to the pending Wastewater Laboratory Analysts Certification program.

The CWPAA recognizes the need for trained and certified analysts and operators and to operate the Wastewater laboratory’s of the state. With a major focus on advanced waste treatment to remove nitrogen from Long Island Sound and the Nitrogen Credit Trading Program we all realize the importance of proper sampling and analysis.

The field of wastewater treatment is constantly changing in response to technology and the demands placed upon the water quality professionals. In today’s environment we are constantly being called upon to do more with less. We are faced with the challenge of ever increasing demands placed on both people and equipment while seeing our operating budgets decline.

We believe that the success of implementing the aforementioned regulations is dependent upon a properly motivated, trained, and educated workforce. There are a number of issues that we have concern over that may hinder the effective implementation of the Program. The impacts of the pending regulations pose both a physical and financial hurdle. Many plants are still attempting to comply with the changes to the Wastewater Treatment Facility Operator Certification Regulations that came into effect June 5, 2000.

As you move forward with the implementation of the Program you need to be aware of the impacts they will cause. The Laboratory regulations will affect a large number of operators and analysts especially at small to medium size plants. These plants represent the majority (65% of the plants in the state are a design flow of 5.0 MGD or less) of the plants in the state. They tend to utilize -operators as analysts in various rotations to cover laboratory operations. These plants will face both a financial and scheduling strain in providing 90 hours (15 days) of training for each operator or analyst involved in sampling, process testing and Class 1 testing. Typically the larger plants have dedicated laboratory staff and do not use operators for process testing so this requirement has the largest impact on smaller plants.

The 5 four-hour sampling course will not cause a scheduling or staffing problem since the time requirement is not excessive. Offering training across the state at various geographical locations would be beneficial. The 45-hour process testing course requirement creates a number of problems. All plants will in effect lose each employee for 8 days. A full training day allows only 6 contact hours. It will be impossible for some plants to commit employees for this length of time. Small treatment plants with a handful of employees will not be able to comply.

The CWPAA questions how the 45-hour process course duration was derived. But the requirement for a 45-hour process course seems excessive. This is nearly the equivalent of a 3-credit college course. The CWPAA consulted with wastewater professionals that do training in the state for their recommendation. Their recommendation is the sampling and process courses are combined into a process-sampling course in the duration of 12 to 15 hours. This is ample time to cover the necessary basic wastewater sampling and process control testing. These courses should be held at WPCFs.

The requirement for CEUs to obtain the class 1 to 4 analysts certification should be accompanied with resource listings for both classroom training and/or correspondence courses that would be acceptable. The identification of correspondence courses for the Class 1 Analyst certification is the most needed since this is the most populated classification.

Of concern is the planned utilization of the state’s community colleges in providing some of this training. We are currently faced with declining enrollment through the colleges in respect to the wastewater courses. Many municipalities will have a difficult time funding a college course, and requiring employees to attend. We also need to be aware of the issue of training scheduling outside of normal working hours. There are a number of plants that run multiple shifts or rotating shifts. Plants would have to cover the shifts with overtime and many municipalities have restricted overtime funding.

We would like to see water quality professionals called upon to aid in providing this training. Between the various entities, ASRWWA, CTLAN, JEITCC, NEIWPCC, and NEWEA we have a number of wastewater professionals that have the credibility and hands on experience to provide this training.

Across the state we have a number of large WPCF’s that are able to accommodate this type of training. This would require coordination between the training agency and the host facility. This environment is most conducive for this level of training. Both the sampling and process-testing course should be available at wastewater plants.

The definitions for the "Chief Operator" and "Chief laboratory analyst" may have some conflicts. For instance who has ultimate and legal responsibility for signing the WPCF DMRs. Normally the Chief Operator would, but the laboratory data will no longer be under his control because the Chief Laboratory Analyst is in charge of the laboratory operation and the data produced. Who determines the location for sampling for process control or NPDES permit testing? Now every WPCF will have two Chiefs neither with ultimate responsibility.

The timetable for implementation of and meeting the requirements of the regulations need to be investigated. The overall issue of training sites, trainers, and the associated impacts upon the municipalities need to be addressed prior to the regulations coming into effect. The CWPAA supports the concept of applicable training and certification so that our operators and analysts are prepared to meet the challenges that are ever changing. We look forward to working with your department and the Certification Advisory Committee to produce a product that accomplishes the objectives while being cognizant of the aforementioned issues. As State Association President, I look forward to meeting with you directly to review this issue in more detail, please contact me directly at your earliest convenience to schedule a meeting.

We hope that our Position Paper will be helpful in your final deliberations on the Wastewater Laboratory Analyst Certifications. Thank you in advance for your attention in this matter.

Sincerely yours,

_______________ Board of Directors- CWPAA

President CWPAA

Carl G. Almquist _____________________

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