Natural Resources and Environment:
Better Planning Can Reduce Size of Wastewater Treatment Facilities, Saving Millions in Construction Costs
CED-82-82, Jul 8, 1982
GAO conducted a review to evaluate the effectiveness of the facility planning process for constructing wastewater treatment plants and to determine whether changed conditions, such as increases or decreases in population projections or industrial flow for proposed service areas, were recognized and incorporated into the facility plans before the plant was designed or before construction started.
GAO estimated that about $30 million in grant funds could be saved if the Environmental Protection Agency's (EPA) 1978 facility planning regulations were applied to the 13 facility plans reviewed by GAO. These facilities were developed under pre-1978 regulations, but are not yet under construction. Current regulations limit the engineering judgment in calculating domestic and industrial flow allowances. However, under the 1978 regulations, EPA stipulated that state population projections would be the sole basis for estimating future population levels to be served by a proposed treatment system. If the 1978 regulations were applied, 11 of those 13 proposed plants would be smaller and 2 plants would be larger. The Municipal Wastewater Treatment Construction Grant Amendments of 1981 provide that no federal grant will be made to construct treatment works which provide reserve capacity in excess of the needs which existed on the date of grant approval. In addition, the amendments reduce federal participation from 75 to 55 percent of the construction costs. Many facets of facility planning are not covered by guidance or regulation. As a result, engineering judgment, which varies considerably from project to project, becomes the deciding factor in determining plant size and project cost. Additional criteria are needed to assist in the determination of proper plant size and to provide plan reviewers a basis on which to evaluate the adequacy of a plan.
- Review Pending
- Closed - implemented
- Closed - not implemented
Matter for Congressional Consideration
Matter: Congress should direct the Administrator, EPA, to modify the agency's current policy prohibiting the retroactive application of program regulations. This can be accomplished by including in the appropriation of funds for the program for fiscal years (FY) 1982 and 1983 language that provides that any grant funds appropriated in the act should fund excess capacity only to the extent that such capacity is consistent with the criteria set forth in EPA regulations at 40 C.F.R. 35.900.
Status: Closed - Not Implemented
Comments: Congress did not pass legislation to implement this recommendation. Legislation was needed in FY 1982 or 1983 for this recommendation to be effective.
Recommendation for Executive Action
Recommendation: The Administrator, EPA, with the cooperation of the engineering community, should develop standards for each critical factor used in establishing existing as well as future domestic, industrial, and infiltration and inflow amounts to be treated by a wastewater plant. Deviations should require additional justification by the consulting engineer to provide EPA with a basis for evaluating the proposed change. As a minimum, these standards should establish: (1) a discharge ratio to be applied to actual water use records when determining existing and future domestic flow to the plant for treatment; (2) a method to be used in measuring industrial flow; and (3) inflow estimates based on a worst storm event experienced in a specified time period.
Agency Affected: Environmental Protection Agency
Status: Closed - Implemented
Comments: EPA conducted an internal control review in 1984 and put a financial capability policy into effect in Febraury 1984. The policy standardized the application and approval process. Grantees must specify costs and funding sources and calculate the average cost per customer. Ratios of planned and existing flow are used by states to evaluate the grant applications.