DOD Can Make Further Progress in Controlling Pollution From Its Sewage Treatment Plants

NSIAD-84-5: Published: Feb 3, 1984. Publicly Released: Feb 3, 1984.

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GAO evaluated Department of Defense (DOD) efforts to control pollution from its sewage treatment plant operations and attempted to determine whether DOD plants are meeting Environmental Protection Agency (EPA) discharge permit requirements.

GAO found that, while DOD has made great efforts to improve its sewage treatment plants, these efforts have not been fully successful because: (1) the services have not always selected the most cost-effective treatment methods available; and (2) plant upgrades and modifications often have serious design and construction flaws that reduce plant efficiency. Major upgrades have occurred in the last 10 years at 11 of the 13 plants visited by GAO, but many of the upgraded plants are not meeting the sewage treatment levels expected because of design deficiencies. In addition, 11 of the 13 plants had been unable to consistently meet National Pollution Discharge Elimination System permit requirements. GAO identified problems leading to noncompliance, including: (1) lack of specific guidance on how to ensure adequate operation, maintenance, and compliance; (2) lack of follow-up on problems found by DOD, EPA, and state environmental inspectors; (3) equipment deficiencies; (4) infiltration and inflow problems; and (5) deficient operation and maintenance practices.

Recommendations for Executive Action

  1. Status: Closed - Implemented

    Comments: DOD does not intend to include a requirement for operating manuals in the 1391's. However, it modified its procurement instructions to require that all contracts require operating manuals.

    Recommendation: The Secretary of Defense should revise DOD and service regulations to require a provision for operations and maintenance manuals to be in all military construction authorization documents, 1391's, for improving sewage treatment.

    Agency Affected: Department of Defense

  2. Status: Closed - Implemented

    Comments: DOD established procedures to ensure that identified deficiencies are corrected and followed up on. These include A-106 reporting, the Defense Environmental Status Report, and Operation, Maintenance, and Training Assistance Program (OMTAP) guidance.

    Recommendation: The Secretary of Defense should require the service secretaries to establish some formal means of ensuring that deficiencies identified at sewage treatment plants are followed up and corrected in a timely manner.

    Agency Affected: Department of Defense

  3. Status: Closed - Implemented

    Comments: DOD has implemented and nearly completed a pilot project. A guidance document, based on results of the pilot project, will be issued for use by all of the services.

    Recommendation: The Secretary of Defense should direct and assist the services as necessary to provide more specific guidance to their bases on how to ensure adequate plant operation and maintenance in order to be in compliance with permit requirements.

    Agency Affected: Department of Defense

  4. Status: Closed - Implemented

    Comments: One of the pilot test projects has been eliminated and the other has been delayed because of funding problems.

    Recommendation: To guarantee that the most cost-effective sewage treatment methods are used, the Secretary of Defense should study the pilot test making one party responsible under contract for designing and constructing a treatment plant and for demonstrating, with plant operators, that the plant will meet discharge permit requirements before turning over the plant to the services for operation.

    Agency Affected: Department of Defense

  5. Status: Closed - Implemented

    Comments: DOD issued new policy instruction. The services are implementing the new policy.

    Recommendation: To guarantee that the most cost-effective sewage treatment methods are used, the Secretary of Defense should require the services to provide written justifications supporting the selection of sewage treatment alternatives that differ from those recommended by cost-effectiveness studies.

    Agency Affected: Department of Defense

  6. Status: Closed - Implemented

    Comments: DOD issued new policy instruction. The services are implementing the new policy.

    Recommendation: To guarantee that the most cost-effective sewage treatment methods are used, the Secretary of Defense should ensure that the services comply with DOD policy by carefully evaluating all feasible treatment alternatives, including regional or municipal tie-ins.

    Agency Affected: Department of Defense

  7. Status: Closed - Implemented

    Comments: DOD implemented a plant operator apprentice program and is implementing OMTAP.

    Recommendation: The Secretary of Defense should work with the Office of Personnel Management to revise the staffing guidelines for sewage treatment plants because of the ever increasing complexity of the treatment plants and processes.

    Agency Affected: Department of Defense

 

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