6
Training Operators for Small Systems

Competent operating personnel are vitally important to the sustained, safe operation of small water systems. Accordingly, good operator training is as essential to improving small water systems as are improved technologies, organizational fixes, or regulatory oversight. Without adequately trained personnel, even a well-financed and organized system with the most advanced technology and regular compliance visits will fail to reliably deliver safe drinking water to its customers.

Unfortunately, the training available to most small system operators falls far short of meeting their needs. This training deficit became especially evident in the early 1990s, when violations of the Safe Drinking Water Act (SDWA) began accumulating in the U.S. Environmental Protection Agency's (EPA's) Federal Reporting Data System. Between 1989 and 1994, the number of community water systems violating the SDWA increased by a third, from 12,295 to 16,779, and the number of violations they incurred more than doubled, from just over 40,000 to over 88,000.

The mounting number of violations made it clear that many small system operators found it difficult to comply with the increasingly complex regulations introduced by the 1986 SDWA amendments. Congress and others involved in passage of the SDWA and its 1986 amendments had assumed that operators either had or would easily acquire (presumably from existing state programs) the skills necessary to comply with the expanding regulatory requirements they faced. However, most small system operators come to their positions through circuitous routes, with relatively little formal training (see Box 6-1 for a typical example).



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--> 6 Training Operators for Small Systems Competent operating personnel are vitally important to the sustained, safe operation of small water systems. Accordingly, good operator training is as essential to improving small water systems as are improved technologies, organizational fixes, or regulatory oversight. Without adequately trained personnel, even a well-financed and organized system with the most advanced technology and regular compliance visits will fail to reliably deliver safe drinking water to its customers. Unfortunately, the training available to most small system operators falls far short of meeting their needs. This training deficit became especially evident in the early 1990s, when violations of the Safe Drinking Water Act (SDWA) began accumulating in the U.S. Environmental Protection Agency's (EPA's) Federal Reporting Data System. Between 1989 and 1994, the number of community water systems violating the SDWA increased by a third, from 12,295 to 16,779, and the number of violations they incurred more than doubled, from just over 40,000 to over 88,000. The mounting number of violations made it clear that many small system operators found it difficult to comply with the increasingly complex regulations introduced by the 1986 SDWA amendments. Congress and others involved in passage of the SDWA and its 1986 amendments had assumed that operators either had or would easily acquire (presumably from existing state programs) the skills necessary to comply with the expanding regulatory requirements they faced. However, most small system operators come to their positions through circuitous routes, with relatively little formal training (see Box 6-1 for a typical example).

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--> BOX 6-1 Genesis of a Small System Operator: A Typical Story This operator's first involvement with small water system operation began shortly after her family moved to a small community located outside a medium-sized city. Concerned about the community water supply, she volunteered to keep the system's account records. Within a year, she became a volunteer water system operator. A few years later she found herself in the position of operator-in-charge, bearing primary responsibility for system maintenance and repairs, water source development, and treatment operations. Thus, in a very short time she had vaulted from volunteer bookkeeper to operator-in-charge, with little qualification other than her interest in the quality of her community's drinking water. Characteristically, she received little formal training to prepare her to undertake the significant public responsibilities of her new position. The states have struggled to meet the training needs of these small system operators. Limitations of Existing Training Programs The reasons for the training deficit among small system operators are many. To begin with, the training available to small system operators is often provided haphazardly through a mix of state-run workshops or seminars, informal instruction from state regulators during on-site inspections, and (in some cases) training provided by technical schools, university continuing education courses, American Water Works Association (AWWA) courses, equipment vendors, or rural water associations. These programs are not coordinated in any meaningful way. In addition, the remote location of some small systems, the part-time or volunteer status of most small system operators, and the cost of reaching and attending training courses discourage these operators from taking advantage of these resources. Perhaps more important, most water treatment operator training programs are designed for operators of medium and large systems and thus fail to give small system operators the combination of broad general knowledge and hands-on practical training they need. Most courses provide general training of a depth that goes beyond what a small system operator will ever require, yet skip many operational basics. For instance, many beginner training classes include extensive sections on complex water treatment processes that few operators of very small systems will ever use. Similarly, most operator training programs (as well as many state certification requirements) cover general technical aspects of numerous water treatment technologies, some of them quite advanced while operators of smaller

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--> systems need specific, hands-on training in only the one or two relatively simple treatment technologies their systems use. Thus, the operator of a system that uses a ground water well and a simple disinfection technology such as chlorination may be trained and tested in multiple advanced technologies appropriate only for larger, surface water systems. Meanwhile the course will offer no training in the challenges the small system operator often faces, such as how to fix a chlorinator, how to take monthly samples without contaminating them, or how to fix and refill a water main without contaminating the entire system. Further aggravating the situation is a lack of consistent training standards and certification requirements across the nation, which makes it difficult for small system managers or operators to even determine if the operators need training. Educational requirements for small system operators can be quite minimal; some states do not even require that operators have high school diplomas. Most operators appear to be particularly undertrained in management and administration. Good management and administration are as essential to sustained system operation as are treatment and distribution issues, but most states have no established minimum requirements regarding these management and administration issues, and most training and testing programs ignore them. All of these problems seriously compromise training of these thousands of small system operators across the country, especially for operators of the very small community systems (those serving fewer than 500 people). For them in particular, the available training usually fails to be either comprehensive or specific enough to meet their needs. This training shortfall constitutes a major threat to the safe and sustained operation of the nation's small water systems and to the ability of those systems to meet the standards of the SDWA. The rest of this chapter will look at the network of present training resources and examine how they can be improved and coordinated to provide more adequate training for small system operatorsûa task in which the EPA can play a key role. State Programs Operator training and certification activities have been an integral part of state drinking water programs for many years. All 50 states currently have operator certification regulations in place. According to a 1995 survey conducted by the Association of State Drinking Water Administrators (ASDWA), 49 of the state programs are mandatory. Forty-nine of the states require operators to pass an exam, 50 require experience, and 47 have educational requirements in place. Forty-six of the states require that certificates be renewed every 1, 2, or 3 years. In addition, 37 states currently require operators to obtain continuing educational credit for certificate renewal. Some states exempt operators of very small systems from some or all of these requirements. In general, state certification requirements for small system operators tend to suffer from the problems described earlier—a failure to be specific to the needs of small system operators, lack of

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--> BOX 6-2 The Illinois Water Operator Certification Program The Illinois water operator certification program is in many ways a typical state program. State regulations require all public water supply systems within the state, except for a few state-owned or -operated facilities and certain communities that buy treated water from another supply, to have a certified operator. Four levels of certification may be achieved by acquiring varying amounts of appropriate experience and passing standardized tests. The certification levels increase in difficulty from distribution system operation only (class D) to the lime softening and filtration of surface waters (class A). The minimum educational requirement is the completion of grammar school, with the experience credit granted to those with higher levels of education. Like tests in most states, Illinois certification tests determine competency primarily in the technical aspects of treating, testing, and distributing potable water, with some attention paid to regulatory knowledge, recordkeeping, and reporting. Little administration or management knowledge is tested. emphasis on areas of expertise other than treatment and distribution, and inconsistency in educational requirements. Box 6-2 describes a fairly typical operator certification program, that of the state of Illinois. In an attempt to supply operators with the knowledge necessary to become certified, the states have taken the lead in training small system operators. In fact, state training programs supply virtually all of the training that operators of the smallest systems receive, yet states are short of the personnel needed to conduct adequate training. According to preliminary analyses of a resource needs model developed by the ASDWA and EPA, states employed approximately 2,160 full-time employees, or full-time equivalents (FTEs), in fiscal year 1992 for drinking water program activities. Of that number, 76 were dedicated to training and development activities and 82 were dedicated to operator certification activities, for a total of 158 FTEs. The model projected that by fiscal year 1995, states would need 113 FTEs for their operator certification programs, 42 FTEs for operator certification assurance activities, 78 FTEs for ongoing training activities, and 34 FTEs for rule-specific training, for a total of 267 FTEs. States have developed a number of tools to train and certify operators. These include newsletters informing operators of changes in state and federal regulations; information mailings and documents related to specific rules; training seminars and workshops provided directly by the state; state participation in and notification of workshops and seminars provided by other organizations, such as the AWWA and National Rural Water Association state affiliates; and certification exams held around the state. In addition, many states review the status and capabilities of operators as part of their state sanitary survey processes. During

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--> BOX 6-3 Other Training Resources In addition to the states, the National Training Coalition, and the National Environmental Training Center for Small Communities, several other sources also presently deliver some training to small system operators. The National Rural Water Association (NRWA) is the national body of state rural water associations, with a primary mission to train and assist small water system professionals on matters of drinking water and wastewater treatment. Most of the training is done by technical ''circuit rider" staff who make on-site technical assistance visits. However, staffing on these associations is usually limited to no more than one circuit rider per state, so they cannot provide training in any depth for operators of the smallest systems. The American Water Works Association (AWWA) offers training programs, but these are aimed at operators of more advanced and larger systems and are usually too expensive, inaccessible, or technically specialized or advanced for small system operators. Technical schools, community colleges, and university extension services offer additional sources of training; these are typically used by operators of larger small systems (those serving between 3,300 and 10,000 people). Such training usually takes the form of a continuing education class rather than a comprehensive training course. These courses generally meet only a narrow need, and (partially because they usually require a tuition payment) tend to reach only the most aware and motivated operators or those who work for larger systems inclined to pay tuition. Equipment vendors sometimes provide training, either on-site or in seminars organized through NRWA state affiliates, AWWA sections, or state initiatives. But as might be expected, these courses are usually limited to the equipment sold by the vendor in question and rarely cover areas beyond treatment and distribution. these inspections, state staff visit the water utilities and work with operators to answer questions and provide additional training. As noted earlier, these programs constitute the sole training for most small system operators. In tandem with the national programs described below, these state programs make a logical starting point for creating a more coordinated and comprehensive small system operator training network. (These state efforts are also supplemented by training programs from schools, associations, and vendors, which could also play important but less central roles in a more coordinated network; those programs are described in Box 6-3.) National Programs On a national level, two recently created groups now seek to address operator training inadequacies; both could play roles in creating a more coordinated, comprehensive training network.

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--> The National Training Coalition The primary goal of the National Training Coalition (NTC) is to promote cooperative work, through its six member groups, to help develop state training coalitions (NTC, 1995a). The NTC's members include the AWWA, ASDWA, the EPA, the National Environmental Training Association, the National Rural Community Assistance Program, and the National Rural Water Association. In 1991, the NTC conducted a national survey of state and federal drinking water regulatory agencies and held two regional fact-finding workshops. The survey and workshops revealed that while most states had active regulatory training programs, there was little formal coordination and cooperation among the organizations, agencies, and institutions providing the training. The NTC found that this lack of coordination and cooperation created a duplication of efforts, conflicting training for operators, and confusion regarding proper procedures and regulatory interpretation. The survey found that both state and federal drinking water administrators felt that existing training efforts were not fully meeting the needs of water system operators (NTC, 1995a). In a follow-up survey conducted by the NTC in 1994, the majority of respondents indicated that the main focus of training programs throughout the country was to provide information on future drinking water regulation. This finding suggests that a priority has been placed on regulatory compliance at the expense of operational performance in most training programs. The survey further revealed that the main needs of training providers include funding, training resource materials, and adequate staff devoted to the effort (NTC, 1995b). The National Environmental Training Center for Small Communities The National Environmental Training Center for Small Communities (NETCSC) was initially established to support the EPA's administration of the Clean Water Act. The center's mission was subsequently expanded to include drinking water and solid waste management. The stated mission of the NETCSC is to support environmental trainers in their efforts to improve the quality of wastewater, drinking water, and solid waste services in small communities. In 1994, the NETCSC conducted a survey of small community environmental training experts concerning issues and trends in small community environmental training. The survey's report, Small Community Environmental Training: Trends-Issues, reveals 25 trainers' perspectives on the status of environmental training in small communities. According to nearly half the survey respondents, the people who most need training often do not receive it. One respondent noted that the logistics of providing training to 57,000 small community systems across the nation are overwhelming (NETCSC, 1994). A small community's ability to afford needed training was highlighted as a concern by two-thirds of the survey respondents.

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--> Proposed Improvements for Training Programs To provide better training for small system operators, it is first necessary to examine the tasks such operators normally perform. Typically these operators must perform a wide assortment of work (see Box 6-4). It has long been widely believed that a small system operator must exhibit competence in only two broad technical areas, treatment and distribution, for a system to be viable. However, while these two areas are important, a small system operator also needs to be competent in administrative, financial, customer service, and other skill areas. A good operator is a "jack of all trades." Table 6-1 presents a task analysis of eight typical small system operator skill areas. Although it is beyond the scope of this chapter to establish specific benchmarks for training competency, the table illustrates the considerable depth and breadth of knowledge a small system operator might require. The type and depth of knowledge needed, of course, vary considerably according to the size and nature of the small system, which by definition might serve a population as small as 25 people (15 connections) or as large as 10,000. The water consumption associated with these systems would vary from less than 2,500 gal per day to close to 2,000,000 gal per day, while the number of personnel required would vary from one par- or full-time operator to a staff of 12 or more. In 1991, the Association of Boards of Certification recognized the importance of the additional areas of training through the establishment of "Need to Know" criteria. The association has begun to use the criteria in standardized tests for small and very small system operators in three states. BOX 6-4 A Small System Operator's Typical Day: December 12, 1995 Because Joe is a township supervisor and township employee, as well as the local water system's certified water treatment plant operator, this winter day began very early. His first duty, at 4:00 a.m., was plowing snow along township roads for school bus transit and other traffic; at one point his truck lost its brakes, causing him to have to ditch the truck to stop it. It was 9:00 a.m. before he got the truck out and could get to his other duties. At that point he was ready to check his water treatment plant. He began by checking the chlorine monitor to see if it indicated a satisfactory chlorine residual at the entry point to the water distribution system; it did. He then noted the turbidity of the surface water source, checked the flow of the raw water source at the water meter and recorded these read-outs in the daily record book. After that, Joe checked the treatment plant's chlorinator and solution tank, and noted in the log that the pump was working properly and the solution tank nearly full. He then performed calibration checks on chlorine and turbidity. Finally, he ran his routine checks on the distribution system, which took less than a half-hour.

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--> TABLE 6-1 Small System Operator Task Analysis General Work Area General Work Item Specific Work Items Associated Knowledge Desired Source and supply Selection Economics Operational costs and manpower requirements, economic evaluation, recordkeeping and reporting requirements, water quality analysis and interpretation, contamination risk     Quality     Adequacy   Maintenance Protection of quality and quantity Withdrawal and source protection regulations, reservoir management, zoning, quantity assessment, quality analysis, treatment Treatment Process selection (including point-of-entry devices) Economics Economic evaluation of operation costs, history of process performance and operation requirements, contingency plan if initial process fails     Reliability     Ease of operation     Performance   Operation and maintenance Continuous Staffing requirements and planning, process performance under differing conditions, chemistry of chemicals employed, safety, laboratory analysis, quality regulations, automated control and monitoring of system operation, computer applications, recordkeeping and reporting regulations, emergency response planning and implementation, contingency planning and implementation, customer protection procedures, maintenance skills for equipment installed, maintenance planning, inventory planning and control     Intermittent     Chemicals and chemical handling     Laboratory and quality control     Automation     Emergency response     Preventive maintenance     Inventory

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--> Distribution Operation and maintenance Flushing Flushing plan, fire-flow rate determination, water quality determination, traffic control, equipment operation, trench safety, repair procedures, repair disinfection, customer protection (boil order issuance) procedures, system database, emergency response planning and implementation, contingency planning and implementation, hydraulic modeling, inventory planning and control, system performance and condition regulations, leak detection and location methods, recordkeeping and reporting, storage tank operation and maintenance, lead and volatile organic chemical paint regulations, booster station operation optimization     Repair of service mains, valves, and hydrants     Installations of new service mains and services     Emergency response     Automation     Inventory     Storage     Booster stations     Cross-connection control   Maps and records "As built" system maps Drawing interpretation and preparation, filing and retrieval, main and service line locations and marking     System performance     Location requests

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--> General Work Area General Work Item Specific Work Items Associated Knowledge Desired Meters Justification Expense allocation Cost-benefit analysis, billing procedures, water loss accountability, water conservation methods   Reading Economics Reading procedures, reading equipment     Manpower availability   Operation and maintenance Economics Meter installation, meter testing, meter repair, meter tracking     Installation       Maintenance       Replacement   Customer service Customer needs Complaint/inquiry investigation and solution Customer interaction skills, remedy alternatives, customer accounting methods and procedures, rules of service, collection procedures, survey techniques, new customer customer establishment     Emergency response     Customer accounting and collections     Customer expectations determination     New customers Finance Payroll Hourly and salaried employees Time accounting, work classification and rate, expense allocation

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--> Accounts payable Materials Purchase procedures, payment procedures   Supplies     Utilities     Services     Damages   Accounts receivable Sold inventory or surplus Sales procedures, collection procedures   Sold services     Damage to facilities   General ledger Chart of accounts Intermediate financial accounting, recordkeeping procedures, state regulation (if applicable)     Assets     Liabilities     Income accounts     Expense accounts     Equity accounts   Funds acquisition Acquiring loans Basic financial accounting, tax regulations, state regulations, loan and grant programs   Acquiring grants   Private company requirements Depreciation     Common income     Accruals     Taxes  

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--> General Work Area General Work Item Specific Work Items Associated Knowledge Desired Human resources Staffing levels Determine proper levels Task analysis   Staffing qualifications Determine necessary job qualifications Determine optimum match of job and employee qualifications Administration Risk control Safety and environmental audits Insurance level determination and purchasing, risk analysis, risk reduction     Risk analysis       Insurance       Risk control     System performance analysis Performance benchmarks Determination of industry performance benchmarks, setting and achieving performance goals     Performance goals and monitoring     Planning Capital Strategic and long-range planning of all business factors     Growth       Expense       Revenue       Emergency  

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--> Two general relationships characterize how system size affects necessary operator expertise. First, as the size of the system increases, and with it the number of employees, the number of job areas in which each employee must be proficient decreases. Second, as the size of the system increases, the depth of knowledge in each individual's focus area usually increases. In other words, small system operators require basic knowledge of all the job areas (from source and supply to administration), while the more specialized (and numerous) operator-employees of large systems must each possess detailed knowledge of a narrower range of skill areas. The ideal training program for any size system, therefore, would divide the skills into a number of areas, each with several skill layers, each layer more advanced than the previous. This approach could be visualized as a training matrix such as that shown in Table 6-2. On the vertical axis are skill areas, and on the horizontal axis are the levels (depth) of accomplishment or difficulty. The operator of a small system would generally train in many areas (vertical alignment), while employees of a larger system would tend to train more vigorously in fewer areas (horizontal alignment). The training matrix in Table 6-2 could be used as a starting tool to organize and detail the skills that must be mastered for safe and sustainable plant operation of systems of different sizes. It is important that no matter what the size of the system, the entire range of skill areas be covered. As mentioned before, training typically has addressed primarily distribution and treatment concerns, without considering the wider, more general requirements for system sustainability. A more comprehensive approach will be more successful in the long run. Training geared towards improving skill areas that are presently underemphasized (meters, customer service, financial, administration, and human resources) will greatly benefit most small systems. Future training programs should use a comprehensive approach covering all areas at depths appropriate to each system's size. State agencies could play an important role by requiring operator, management, and system certification. The system certification could be linked to the annual operating permit discussed in Chapter 5. In establishing certification standards, states should recognize that the full complement of identified skills are necessary to provide a sustainable operation. Failure to provide competency in all areas may, in many cases, lead to an unsustainable system and eventual failure to protect public health through compliance with the drinking water regulations. Any certification requirement should therefore include not only the technical operation skills, but also the other important skills identified. Competency in these areas could be proven through state-conducted performance assessment testing, successful completion of required courses, other advanced certifications that include the necessary content (for example, a professional engineering or accounting degree), or assignment of the work to a qualified professional. The technical treatment competency requirements for a small system operator should be limited to a basic understanding of public health concepts, applicable

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--> TABLE 6-2 Training Matrix: Examples of Training Levels Skill Level 1 Level 2 Level 3 Source of supply Quality tests, regulations Watershed survey Economics and long-range planning Treatment Specific process used, regulations Other treatment processes Economics and process selection Distribution Main repair, regulations Pump repair, control systems Hydraulic modeling Meters Meter reading Meter repair Automatic meter reading, economics Customer service Answering customer questions Scheduling customer service activities Determining customer desires Financial management Billing, collections Payroll, general ledger Rate design, borrowing Administration Sustainability System growth System operation as a business, lobbying for favorable legislation Human resources Safety Hiring, firing, employment regulations Total quality management concepts regulations, source protection, distribution system operation, and competency only for the actual treatment process(es) the operator's system employs. It does little good to require small system operators to learn processes they will likely never use; indeed, such a requirement actually may discourage such operators from seeking certification. At the same time, however, small system operators will need to have some knowledge of how the particular treatment process or processes used in the plant function. An understanding of the principles by which the process operates is important for responding to system malfunctions; knowing how to turn handles and record meter readings is not enough to recognize and address operating problems. If the operator does not have sufficient understanding of the treatment process, then such expertise must be available to the operator on short notice from a circuit rider, consultant, larger water utility, state agency representative, or another source. Illinois already uses this type of system-specific certification program for industrial wastewater treatment plant operators. The state issues a "class K" certificate valid only for specific plants; the examination tests the applicant's

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--> knowledge of principles, techniques, permit requirements, math, and safety, in addition to requiring a flow schematic of the applicant's particular plant. The test is geared towards testing the applicant for knowledge crucial for operation of his or her particular plant and certifies the operator for only that plant (Illinois Environmental Protection Agency, 1983). The Illinois system-specific technology certification program may provide a good model for treatment certification programs in other states. Of course, advanced treatment certifications covering many treatment processes should remain available for larger system operators, more ambitious small system operators, and circuit riders exposed to a wide and varying assortment of processes and situations. Implementation Improving small system operator capabilities will require significant changes in the training available to those operators. Such changes will not occur without a well-orchestrated effort at the national level, including a substantial and continuing commitment of resources. Developing and delivering a comprehensive, nationally available training program will also require a leadership agency to guide the effort. This is a vital role the EPA can and should fulfill, and the Committee on Small Water Supply Systems strongly recommends that the agency do so. It is clearly within the EPA's mandate to provide technical assistance in support of the goals established by Congress under the SDWA. The SDWA Amendments of 1986 authorized the expenditure of up to $15 million per year to provide technical assistance to small systems struggling to comply with the requirements of the act. The EPA currently provides $6.5 million annually to the National Rural Water Association and the Rural Community Assistance Program for technical assistance to small water systems. However, this funding has not resulted in the development of coordinated training programs for improving the knowledge and skills of small water system operators. Historically, the EPA has had to concentrate on regulatory compliance at the expense of developing programs for improving operator performance. Focusing on operator performance may more efficiently address the fundamental issue, which is improving water supply. To fulfill this recommendation, the EPA should establish an organizational work unit, based at headquarters, responsible for identifying desirable knowledge and skills for the successful operation of all aspects of drinking water systems; arrange for the development of multimedia tools to effectively deliver the needed training to system owners and operators across the country; and support efforts to coordinate and deliver training programs to operators of

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--> all system sizes and types and in dispersed geographic locations. (This training would not include regulatory compliance, since that will vary from state to state.) Obviously, these recommendations require a commitment of funds. Recognizing that new funding resources may not be available, this recommendation could be readily accomplished simply by reprioritizing resources already under the agency's control so that training receives as much emphasis as to development and enforcement of regulations. In this role, the EPA should serve as a facilitator. Ideally, the new work unit would be staffed with experts in innovative training applications who, through the use of partnerships and contracts with experts in the field, would direct the development of interactive training modules in various formats for delivery to small system operators. In doing so, the EPA should draw first upon training materials that are already available through trade associations, public utilities, state programs, and others and are deemed to be of acceptable quality by a panel of expert advisors. Both the NTC and the NETCSC could be vital partners in this effort. These materials should be compiled and catalogued to determine where gaps exist and to establish priorities for creating additional training modules to fill those gaps. Existing materials with acceptable technical content could then be submitted to a contractor with expertise in developing innovative training programs. The EPA would work with technical experts to develop acceptable training modules to fill areas where gaps exist before submitting those modules to the training program contractor. In creating these materials, the unit should draw on experience gained by some state programs and other training providers in the development of effective training programs; here again the NTC could lend valuable assistance. Training providers who are in direct contact with small system operators are well positioned to develop effective, interactive training programs that meet the needs of those operators. Once the modules are completed for the entire program, the EPA would move into delivery mode. The agency should provide and promote access to the training modules as a national initiative. Electronic vehicles (video, computers, etc.) for dissemination should be fully exploited. To ensure that the training materials remain state of the art, the EPA should also have an ongoing program of technical review and modification to incorporate feedback from operators and technical experts regarding quality and relevance. Such an effort could begin to fill the present gap between regulatory requirements and available training. A significant backlog already exists, for instance, with regard to developing the operator skills necessary to comply with disinfection, filtration, and corrosion control processes mandated by existing federal and state regulations. When developing new regulations, the EPA must, as a priority, identify operator skill requirements and training needs early in the process so that

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--> the appropriate training materials can be made available as the new regulations take effect. The states should be designated as the lead agencies for delivering the national training program. The state agencies' organizations, locations, and professionally trained staffs enable them to effectively deliver the training programs. As designated lead training providers, the states would also be responsible for networking and coordinating with other training providers, such as state operator associations, state rural water associations, AWWA state sections, educational institutions, and others able and willing to support the effort. The EPA should vigorously promote such state leadership. Training must be given prominence in annual program grant funding and when negotiating the work plans for primacy program implementation. The EPA also needs to provide easy state access to the training materials and the training program development contractor to meet state-specific training needs. The NETCSC could be the vehicle to institutionalize operator training into the EPA's mission and facilitate its implementation. The NETCSC operates under a cooperative agreement with the EPA. It has three primary functions: serving as the library for training programs and materials developed by state, association, and other providers; developing new multimedia training vehicles; and conducting train-the-trainer courses across the country. The NETCSC has developed several training programs covering key areas of water supply service; these training programs typically employ manuals, books, and videotapes. The center's Train-the-Trainer program could facilitate dissemination of these materials to a broader audience of operators across the country. Conclusions Good operation and management are fundamental to the sustainability of small water systems, yet operators of small systems often lack adequate training. Many regulatory violations and waterborne health risks could be avoided by an increased investment in operator training. Although efforts to train small system operators are beginning to improve, they have a long way to go: Training is often unavailable or inaccessible for operators of very small systems. The remote location of some small systems, the cost of traveling to and attending training courses, and the lack of personnel to serve as back-up operators discourage small system operators from enrolling in training programs. The content of training programs often fails to meet the specific needs of small system operators. Too often, training programs focus on theory and tasks for water treatment that only operators of larger systems need to learn in detail. Training programs often fail to include the multiple key skill areas (treatment, distribution, source of supply, meters, customer service, financial

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--> administration, and human resources) needed to ensure a viable system. Most existing training programs address only treatment and distribution. Resources for supporting training programs need to be increased if operator training is to reach a satisfactory level. Funding, program design, resource materials, and staff all need bolstering. The presently uncoordinated programs could benefit from initiatives like the NTC's efforts to facilitate the formation of state coalitions. Recommendations The EPA should guide the effort to improve training for small water system operators. The EPA should build on the efforts of the NTC and the NETCSC and reallocate resources that implicitly overemphasize enforcement over technical training. Whether with new funds or through reallocated funds, the EPA should (a) establish an organizational work unit to identify appropriate operational knowledge requirements; (b) arrange for the development of multimedia training tools for nationwide delivery; and (c) vigorously support efforts to coordinate and deliver training programs in the field to dispersed operators. State drinking water agencies should be responsible for delivering training programs developed by the EPA. Training will be most effective if it is delivered locally to minimize the need for travel by small system operators. Lead training agencies should prioritize each of the general key training areas and offer training accordingly. States should establish competency benchmarks for all small system work areas. States should rewrite their certification laws for small system operators to emphasize the processes employed by the certified operator's particular system. Requiring more knowledge than necessary from a small system operator wastes his or her time and discourages the pursuit of certification. Operator certification should include classifications not only by system size but also for each of the general skill areas. References Illinois Environmental Protection Agency, Division of Water Pollution Control. 1983. Procedures for Certification of Operators of Wastewater Treatment Works. IEPA/WPC/83-012. Springfield, Ill.: Illinois Environmental Protection Agency. NETCSC (National Environmental Training Center for Small Communities). 1995. Small Community Environmental Training: Trends and Issues. Morgantown, W. Va.: National Environmental Training Center for Small Communities. NTC (National Training Coalition). 1995a. Cooperation, Coordination, Communication, and Compromise… The Keys To Successful Coalition-Building. National Training Coalition Activity Report No. 2. Washington, D.C.: Association of State Drinking Water Administrators, National Training Coalition. NTC. 1995b. Findings of the NTC. Washington, D.C.: Association of State Drinking Water Administrators, National Training Coalition.