Transcript APWA 3-18-10 Presentation

CMOM and Beyond
Overview of the
Proposed SSO Rule
Presented By:
Deborah Chase, CBCP
Phone: (425) 450-6257
[email protected]
Ron Brown, PE, PMP
Phone: (425-450-7104)
[email protected]
Presentation Objective
Update on the previously proposed
SSO rule and how EPA enforcement
of the Clean Water Act (CWA) for
collections systems, operations,
and maintenance impacts municipal
wastewater utilities.
Overview
 SSO Rule & EPA Enforcement
 Operational Program Management
Program Components
Monitoring, Measuring and Modifications
CMOM and Beyond
Overview of the Proposed SSO Rule
SSO Rule & EPA Enforcement
Why EPA Cares About SSOs
 A national problem
 SSOs are widespread.
 SSOs pose health/environmental risks.
 Chronic SSOs reflect inadequate O&M.
 EPA/States sending mixed signals
 Inconsistent/unclear NPDES requirements.
 Response to the national problem
 EPA convened negotiating committee Dec 1994.
 Included municipal, environmental, and state stakeholders.
 EPA committed to considering recommendations;
hence, evolving regulations on SSOs.
SSO Rule Update
 Intended to require Best Management Practices
(BMPs) using proposed CMOM regulation.
Capacity
Management
Operational Practices
Maintenance Practices
 Withdrawn from the Federal Register as enforcing
the Clean Water Act (CWA) was sufficient.
CWA prohibits any avoidable discharge of untreated
wastewater.
EPA’s goal is to eliminate or minimize overflows as
required by the CWA.
EPA Overflow Reduction Strategy
 April 2000: EPA Developed Strategy
 Enforce Using CWA Authority
 Address problems using CMOM concepts
 EPA Regions Develop Enforcement Plan
 ID SSO and NPDES Violators & Establish Enforcement Priorities
 Use Full Range of Regulatory Response Options
 Ensure Action Taken
 EPA Activity in Region 10
 Oregon - Portland, Medford
 Washington - Seattle Public Utilities, King County, Everett
EPA has increased their emphasis on audits
EPA Actions . . .
May 8, 2007
- EPA, DOJ, and State of
Hawaii
JULY 1998
JULY
1998reach agreement
with the City and County of Honolulu to address
vulnerabilities that led to Waikiki sewage spill
May
3,Department
2005 - Metropolitan
Department
HONOLULU
– The
of Justice, the U.S.Wastewater
Environmental Protection
Agency,
the Hawaii Attorney
General’s Agreement
Office, and the Hawaii
Department
of Health
have
City Reaches
on Sewer
Spills
Lawsuit
reached an interim
agreement
with
theof
City
County
Honolulu
will correct
SAN DIEGO
- The
City
Sanand
Diego
hasofreached
an that
agreement
that the
most significant
problems
in Honolulu’s
collection system.
This settlement
ensures
the continuation
of wastewater
the City's successful
Sewer Spill
resolves a civil
enforcement
actionThe
thatconsent
the United
Statessigned
and the
have filed
Reduction
Program.
decree,
bystate
the City,
the against
the city. Surfrider Foundation, the San Diego Baykeeper, and the EPA,
resolves a lawsuit against the City for alleged violations of the Clean
The current agreement is an interim settlement because it addresses only some of the
Water Act from sewer spills. Monies to meet the estimated $187
problems
in the city’s wastewater collection system. In addition to the force mains
May 3, 2005 - Metropolitan Wastewater
Department
million settlement are already part of the Metropolitan Wastewater
City Reaches Agreement on Sewer Spills Lawsuit
addressed in the agreement announced today, the city’s wastewater collection and
SAN DIEGO - The City of San Diego has reached an agreement
Department's
budget.
that ensures the continuation of the City's
successful Sewer
Spill includes many other features which are the subject of other regulatory
treatment
system
Reduction Program. The consent decree, signed by the City, the
and
legal proceedings. As a next step, it will be the intention of the federal and
Surfrider Foundation, the San Diego processes
Baykeeper, and the
EPA,
resolves a lawsuit against the City for alleged violations of the
state governments to attempt to reach a comprehensive resolution to the city’s remaining
Clean Water Act from sewer spills. Monies to meet the estimated
$187 million settlement are already part
of the Metropolitan
wastewater
collection and treatment challenges.
Wastewater Department's budget.
EPA Enforcement Strategy (2008-2010)*
Goals for CSOs
Goals for SSOs
1
2
100% of large & associated
satellite systems addressed
50% of medium & associated
satellite systems addressed
1
2
Address 100% of all combined sewer
systems with 50,000+ population
Prioritize less than 50,000 population
applicable for federal involvement
 Large System = 100 MGD (design flow) or greater
 Medium System = >10 MGD but <100 MGD
* EPA Presentation at PNCWA 9.12.2008
Local EPA Actions . . .
March 2008
EPA audits King County and
Seattle Public Utilities
June 2009
EPA enters Administrative
Orders with King County and
Seattle Public Utilities
August 2009
EPA audits City of Everett
Public Works Department
2010
Who’s Next?
Is Your Agency Ready?
“. . .we need to raise the bar for clean water enforcement
performance . . . we must boost EPA’s enforcement presence . . .
we must assure that we are doing the work that is most important
to clean up our nation’s waters . . .”
-Lisa Jackson, EPA Administrator – July 2, 2009
EPA Enforcement Goals
Aggressively go after pollution problems that make a difference in
communities. Vigorous civil and criminal enforcement that targets
the most serious water, air and chemical hazards; advance
environmental justice by protecting vulnerable communities.
 Clean Water Act action plan: revamp enforcement and
work with permitting to focus on the biggest pollution
problems, including:
 Getting raw sewage out of the water
 Reducing polluted storm water runoff
 Clean up great waters that matter to communities, e.g,
Chesapeake Bay
EPA Proposed Enforcement Strategy
(2011-2013)
Candidate National Enforcement Priority:
Wet Weather Municipal Infrastructure (Jan ‘10)
Infrastructure
Goals
1
1
Combined Sewers
2
Decrease impact on water quality
2
Sanitary Sewers
3
Municipal Separate Storm
Sewer Systems (MS4s)
Encourage utilities to develop a better
way of managing infrastructure by
understanding condition and making
risk-based decisions
Other SSO Reduction Actions
 Stakeholder Lawsuits
Non-Governmental Organizations (NGOs)
 Action Agenda
Partnership to clean up Puget Sound
Typical EPA Audit and Order Process –
Collection System Audit Phase
Letter &
Information
Request
Possible
Supplemental
Info Requests
Comments by
Agency (Usually
Only 30 Days)***
Initial Audit*
Draft Audit
Report**
Final
Audit Report
*Focus on Facts and Data During Audits, Not “War Stories”
**Review Results Very Closely
***Respond regardless of whether it will affect the audit
Typical EPA Audit and Order Process –
Collection System Order Phase
Draft Proposal to
Correct Deficiencies*
Administrative
Order or Possible
Consent Decree
Implement
Programs
Negotiations on
Programs**
Prepare Plans
Required by
Order / CD
Monitor Compliance
and Results
*Often Issued 4 to 6 Months After Final Audit Report
**Can take days or years
Lessons Learned: Capacity Programs
Scrutinize Peaking Factors and Assumptions –
Don’t Be Too Conservative
Consider Different Capacity Upgrade Guidelines
for Existing vs. New Sewers
Field Verify Capacity Issues Identified by Models
Before Finalizing CIP
Wet Weather: Invest in a Detailed Study of Convey
& Treat vs. I/I Reduction Options
Lessons Learned: Inspection and
Condition Assessment Programs
Don’t Inspect Every Sewer in the System (Unless
Needed)
Utilize Risk Analysis to Identify Sewers that
Should be Inspected
Standardize Defect Codes Utilized by Crews and
Contractors; Have a QC Process
Inefficient to Analyze Text-Based Data and Data on
Paper Forms
Lessons Learned: Inspection and
Condition Assessment (Continued)
Code-Based Data Linked to Specific Assets in an
Electronic Format is Easily Analyzed
Data Management is Essential – Have a Strategy
and a System
Develop a Decision Process for Repair,
Rehabilitation and Replacement Projects
Simplified Decision Processes are Easier, But
Results Will Not be Optimal
Lessons Learned: Pump Station and
Force Main Programs
To Support Negotiations, Identify Holding Time
Prior to Spill and Location of Overflow for Each
Pump Station
Consider Generator Connections and Portable
Generators When Appropriate
For Newer Force Mains, Negotiate a Future Testing
or Inspection Date
Lessons Learned: SSO Response and
Notification of Stakeholders
Focus on Average Response Time During
Negotiations, if Possible
Utilize Pump Station Holding Time Data to
Negotiate Pump Station Response Times
Coordinate Notification With State and/or Health
Department
Make Sure Your Internal Records are Consistent
Lessons Learned:
Cleaning and FOG Programs
Need Cleaning Data to Negotiate Reasonable
Cleaning Frequencies
Begin to Collect Cleaning Data re: the Type and
Quantity of Findings in Pipes
Document Hot Spots and Assign a Frequency and
Type of Cleaning
Develop a FOG Strategy & Ordinances
(Inspect, Clean, Educate, or a Combination)
Successful Audit Outcome Preparation
 Meet permitted number of allowable wet weather
discharges
 Strive for 0 dry weather CSO events
 Show a continuous downward trend in SSOs
(goal is 2 or fewer SSOs per 100 miles of pipe)
 Implement continuous improvement programs
 Review each program for effectiveness and make
adjustments as needed
SSO Rule & EPA Enforcement Summary
A High Level of SSOs Gains
Attention from EPA, State, or NGOs
Audits Should Not be Taken Lightly –
Understand the Process and Implications
Adopt BMPs and Develop Programs
that Follow CMOM Guidelines
Data to Support Your Position is Crucial for
Reasonable EPA Negotiation Outcomes
CMOM and Beyond
Overview of the Proposed SSO Rule
Operational Program Management
Wastewater Overflows
 What are SSOs (sanitary sewer overflows)?
 Spilled raw sewage into streets, basements, receiving water
bodies, etc.; flooding from sewer system prior to treatment
 What are CSOs (combined sewer overflows)?
 Excess wastewater discharged through NPDES permitted outfalls
during periods of rainfall or snowmelt when capacity of the sewer
system or treatment plant are exceeded
 What are DWOs (dry weather overflows)?
 Overflows from combined sewer outfalls
during dry weather; prohibited under the
NPDES program
What are Avoidable/ Unavoidable
Conditions
Dry
Criteria
Dry weather
condition
Utility
Avoidable
All are
avoidable
unless
demonstrated
otherwise
≤ Design Storm
Wet
EPA
Unavoidable
> Design Storm
$$$ to eliminate all
unavoidable
Avoidable Overflows Are Caused By:
 Inadequate or negligent operation
 Inadequate system capacity
 Improper system design
Unavoidable Overflows Result From:
 Extreme acts of nature
 Unavoidable third party actions
 Unforeseen/unavoidable structural,
mechanical, etc. failure
 Unforeseen/unavoidable blockages
Estimated SSO Occurrences
 Based on a sample of six communities
 Causes of SSOs can vary significantly from community to community
Power Failure - 11%
Insufficient System Capacity - 7%
I/I - 27%
Pipe Breaks - 12%
Source - EPA website
Pipe Blockages - 43%
Minimum Operational Measures
 Identification and
tracking of overflows
 Immediate response
to overflows
 Proper operation and
maintenance programs
 Public notification as needed
Advanced Operational Measures
 Process to prioritize chronic wet weather and
avoidable dry weather overflows
 Process to identify and monitor system
performance indicators
 Optimization of treatment plant operations during
wet weather
 Separate sewer system specific evaluation
 Long-term remediation evaluation and plan
Best Management Practices (BMPs)
 Know your collection system capacity
 Know your hydraulic bottlenecks
 Know your asset conditions
 Have established procedures for emergency
response and public notification
 Ensure CIP and preventative maintenance
programs address all known deficiencies
Program Components
General
Standards
Completed
Program
Management
Program
Overflow
Response
Plan
Communications
System
Evaluation
& Capacity
Assurance
Plan
Program
Audits
Design Approaches
 Requirements and standards
for installing new sewers,
pumps, etc.
 Procedures and
specifications for
inspecting and
testing installation
of new sewers,
pumps, etc.
Program Tools
 Hydraulic Modeling
 Predictive Modeling - Rehabilitation
Assessment Models
 Decision Analysis
 Field Inspections
 Geographic Information Systems (GIS)
 Master Plan
Management Program Overview






Identify program goals
Identify organization
Establish programs for Utility Responsibilities
Identify measures and activities
Establish design and performance standards
Implement monitoring, measurement,
and program modifications
Overflow Emergency Response Plan
Ensures…
 Awareness of all overflows
 Response to overflows
 Reporting of overflows
 Notification to public, health agencies, etc.
 Trained personnel follow plan
 Provision of emergency operations
Measures and Activities
 Maintenance of facilities and
system map
 Management and timely use of relevant
information to establish and prioritize program
activities
 Cleaning Cycles
 Rehab and Replacement
 CCTV
 Smoke Testing
System Evaluation and
Capacity Assurance Plan (SEACAP)
 Evaluation – Identify portions of system that
experience or contribute to overflows.
 Capacity Enhancement Measures –
Short- and long-term measures to address any
identified hydraulic deficiency.
 Plan Updates – Describe significant change in
proposed actions or implementation schedule and
performance of implemented measures.
Program Audits
 Conduct internal audit as part of NPDES permit
application preparation
Organizational deficiencies - Identify areas within
organization and practices in need of improvement
Identify NPDES violations
Determine number of overflows
Evaluate customer complaints
Communications Participants
2.
Local
Government
1.
Operators
3.
Public Health
Officials
Eliminating
Avoidable
Overflows
Compliance with CWA
4.
NPDES
Authorities
5.
Public
Continuous Program Process
Plan Program
(Including Updates)
Implement
Program
Identify any needed
Program Updates
Analyze/Evaluate
Program
Monitoring, Measurement, and
Program Modifications
 Monitor program element implementation
 Measure effectiveness of each program
element
 Update program elements based on
monitoring/performance evaluations
 Update summary of program
Example Program Results
SSO History (1997-2009)
400
350
Programs
Implemented
# of SSOs
300
250
200
Programs
Modified
150
100
50
0
Year
Suggestions for Improving Programs
 Assess conditions
 Evaluate cost-effective alternatives for repair,
and budget accordingly
 Develop master plan for phased implementation
 Examine user fees and develop programs for
matching them to assessed needs
 Evaluate alternative funding, including grants,
loans, and creative financing techniques
Results in proactive system approach to eliminate avoidable overflows
Questions and Discussion
Typical EPA AO/CD Requirements








Preventive Maintenance to Eliminate (Minimize) SSOs
Fats, Oils & Grease (FOG) Management
Inspection & Condition Assessment
Process to Identify Deficiencies
CIP - Sewer Rehabilitation & Replacement
Capacity Assessment & Assurance
Pump Station Programs
Force Main Programs