TINKER, MIND YOUR TRADE: USE OF SPECIALIZED EXPERTISE SAVES WATERTOWN, S.D. FROM CONTINUING ENFORCEMENT HEADACHES

The City of Watertown, South Dakota was faced with a myriad of wastewater issues that were resolved through a Program Management approach. The success of the Program Management approach was achieved through the work of a number of individuals who contributed by “minding their trade”, that is, focusing on the objectives of their portion of the project and then applying their particular expertise.The City's treatment plant was neither able to consistently meet the discharge requirements of its NPDES permit nor comply with other permit conditions such as laboratory procedures, operations and maintenance, and development of an industrial pretreatment program. The City was issued multiple Administrative Orders from the USEPA plus civil litigation was being initiated by USEPA. Earth Tech was hired to perform an evaluation of the existing treatment process and to determine whether or not the City was truly on a path to compliance.One of the recommendations of the initial study was to hire a program manager to track all required activities to achieve compliance. Earth Tech was retained to serve as the program manager and engineer. When the City was informed that legal action was being considered, the City decided an NPDES/Consent Decree specialist was needed. The City also recognized that any construction would be very costly and have a severe impact on the City's financial resources. This created the need for a national level funding specialist's involvement. Thus, a team of specialist experts was identified to help the City achieve compliance.The Program Manager completed all engineering-related activities and coordinated the entire issue resolution process. The permit/Consent Decree specialist assisted the City in efficiently reaching terms for a Consent Decree that were aggressive but achievable. The funding specialist identified the requirements for all activities to be performed in a fashion to maximize the potential to capture funding. A full plan of needed action items was developed embodied in a Consent Decree, and funding was sought and received from Congress. The City, with the team's assistance, achieved full permit and Consent Decree compliance in four years, and ahead of schedule.A team of experts, each “minding their trade”, and in full cooperation with the City, can achieve many goals under difficult circumstances. The authors summarize the process that was followed and provide some lessons learned from this enforcement case study which provide some tips and advice to other cities that find the enforcement wolf at their door.