M E M O R A N D U M. Among the standard conditions contained in the NPDES permit is also a Duty to

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1 M E M O R A N D U M DATE: August 7, 2015 TO: FROM: SUBJECT: Metropolitan Wastewater Management Commission (MWMC) Matt Stouder, MWMC General Manager Capacity Management, Operations, and Maintenance (CMOM) Program Update ACTION REQUESTED: Information only, no action requested ISSUE Over the last several years, the Cities of Eugene and Springfield have collaborated to develop local CMOM implementation plans. At the August 14, 2015 MWMC meeting, staff from the two partner agencies will share with the Commission the progress they have made in development of their CMOM plans. BACKGROUND Regulatory Obligations of Partner Agencies The cities of Springfield and Eugene each own and have operational control over their respective public wastewater collection and conveyance systems. Wastewater from Springfield and Eugene is combined and treated in regional facilities owned and operated by the MWMC. After treatment, the cleaned water is discharged to the Willamette River in accordance with regulatory requirements described in the National Pollutant Discharge Elimination System (NPDES) permit jointly held by Springfield, Eugene, and the MWMC. In addition to water quality limits and treatment requirements, the NPDES permit contains standard federal permit conditions related to Sanitary Sewer Overflows (SSOs) that apply to all portions of the collection system for which the permit holder has ownership and/or operational control. These provisions include establishing Duty to Mitigate, requirements for proper operation and maintenance of the collection system, noncompliance reporting, and recordkeeping. Collectively, these requirements result in an NPDES permit obligation for the each city to: Eliminate avoidable SSOs Have a program in place to identify and reduce inflow and infiltration into the collection system. Among the standard conditions contained in the NPDES permit is also a Duty to

2 Memo: CMOM Program Update August 7, 2015 Page 2 of 3 Comply which states that any permit noncompliance constitutes a violation of Oregon Revised Statutes (ORS) 468B.025 and is grounds for enforcement action; for permit termination, suspension, or modification; or for denial of a permit renewal application. Additionally, Section 505 of the Clean Water Act authorizes citizens to bring suit in federal district court against violators of the requirements set forth in wastewater discharge permits issued under the NPDES program. MWMC Wet Weather Management History In 1996 the Oregon Environmental Quality Commission (EQC) adopted the Oregon Bacteria Rule to address wet weather related SSOs. Among other things, the bacteria rule required municipalities with separate sanitary systems to submit an acceptable plan to the Department at the first permit renewal, which describes actions that will be taken to assure compliance with the [SSO] discharge prohibition by January 1, Historically, the Eugene/Springfield regional wastewater treatment plant has experienced peak wet weather flows in excess of 10 times the base flow due to rainfall derived inflow and infiltration (RDII). Accordingly, in response to the Oregon Bacteria Rule, Eugene, Springfield, and the MWMC developed the 2001 Wet Weather Flow Management Plan (WWFMP) and submitted it to the DEQ. DEQ approved the WWFMP and subsequently incorporated it by reference into the existing administratively extended NPDES permit, issued in The WWFMP evaluated various alternatives and selected the most cost effective combination of RDII reduction through collection system rehabilitation and expansion of the hydraulic capacity of the regional wastewater treatment plant. The WWFMP, and subsequent 2004 MWMC Facilities Plan, led to approximately: 18 miles of sewer rehabilitation in Springfield 53 miles of sewer rehabilitation in Eugene Approximately $40 million investment at the regional treatment plant to increase hydraulic capacity from 175 million gallons per day (mgd) to 277 mgd to meet projected 20-year peak flow requirements Both cities and the MWMC completed the required rehabilitation and plant upgrades before DEQ s January 1, 2010 deadline. While this work represents a significant milestone, federal and state permit requirements to eliminate SSOs and reduce RDII are expected to remain in place for the foreseeable future. Moreover, as the two communities collection systems age and deteriorate, RDII entering the system is expected to increase over time, which is why regional program staff is working with the two communities to implement a strategy to reduce RDII on a continual basis. CMOM as a Collection System Management Strategy Over the last two decades, CMOM has emerged in the wastewater industry as a strategy to ensure collection system capacity requirements are met, to prolong the life of existing infrastructure, and to ensure sound financial planning in support of the program.

3 Memo: CMOM Program Update August 7, 2015 Page 3 of 3 Beginning in 2011, Regional Wastewater Policy staff from Springfield, Eugene, and the regional program discussed CMOM as a strategy that each city could use to identify future wastewater collection system rehabilitation and repair projects after completion of the projects that were identified in the WWFMP. CMOM was recognized as an effective tool for implementing practices needed to address SSO s, reduce RDII, provide protection against NPDES permit violations and potential citizen lawsuits, and ensure collection system capacity into the future. Staff updated the Commission on CMOM development progress at the MWMC meetings in August 2012, October 2012, November 2013, May 2014, and August Over the course of the two Commission meetings in May and August 2014, regional wastewater program staff worked with the Commission to develop a CMOM Framework Document that outlined the Commission s expectations of the essential elements to be addressed in a CMOM program approach. The approved CMOM Framework document is provided as Attachment 1. In addition to the CMOM Framework Document developed by the Commission, each partner agency performed CMOM gap analyses using the US Environmental Protection Agency (EPA) CMOM Checklist as a guidance tool. The MWMC s consultant, CH2M Hill, also provided guidance for each city in developing their respective CMOM gap analyses. These gap analyses were completed in the fall of DISCUSSION Eugene and Springfield staff have been working to develop CMOM Implementation Plans informed by the CMOM gap analyses that were performed in Each plan describes approaches to address the elements outlined in the MWMC s CMOM Framework Document, which is provided in Attachment 1. Attachments 2 and 3 provide an executive level summary of the City of Eugene and City of Springfield s plans, respectively. At the August 2015 Commission meeting, staff from Eugene and Springfield will summarize operations activities and describe the key elements of their respective CMOM program plans. ATTACHMENTS 1. MWMC CMOM Framework Document 2. City of Eugene CMOM Plan Summary 3. City of Springfield CMOM Plan Summary

4 Regional CMOM Framework Document CMOM Description Capacity Management Operations and Maintenance (CMOM) is an integrated and adaptive planning approach to the management of collection systems. CMOM provides a comprehensive framework to ensure the Cities of Eugene and Springfield have resources and systems to plan and execute work proactively and effectively. The core goal embraced by the MWMC and the Cities of Eugene and Springfield through the implementation of CMOM is to cost effectively protect public health and the environment. Purpose This document is the Commission approved framework for collection system management that serves as a standard for the partner agencies to follow in the management of their respective collection systems to ensure regional goals are met and to comply with agency regulatory requirements. In addition to this Regional CMOM Framework Document, the MWMC has developed a Regional CMOM Guidance Document to support the development and implementation of CMOM programs by each of the Cities of Eugene and Springfield, who independently own and operate the two wastewater collection systems that convey wastewater to the MWMC s regional wastewater treatment system. Regulatory responsibility for collection system management stems from two requirements of the jointly held the National Pollutant Discharge Elimination System (NPDES) permit: 1) Reduction of Sanitary Sewer Overflows (SSOs) to the greatest extent feasible, and 2) Reduction of Rainfall Derived Inflow and Infiltration (RDII) from entering the collection system. The Regional CMOM Guidance Document sets forth the MWMC s CMOM guidance in keeping with the special functions and obligations described below. Regional Wastewater Intergovernmental Agreement Functions and Obligations The MWMC Intergovernmental Agreement (hereafter, the IGA) defines the MWMC s authority to set collection system management standards, which are described in Sections 3 and 8 of the IGA. Section 3 of the IGA describes the Special Functions of the Commission [MWMC]. This includes (under Section 3 (m)): Adopt minimum standards for construction and maintenance of collection systems. Section 8 of the IGA describes the Obligations of the Governing Bodies. This includes (under Section 8 (b)): Adopt as a minimum the Commission s standards for construction and maintenance of sewage collection systems and for pretreatment requirements for industrial and other wastes. ATTACHMENT 1 Pages 1 OF 3

5 By adopting this Regional CMOM Framework Document as the minimum standards for the construction and maintenance of the collection systems, the MWMC acknowledges that the partner agencies themselves are best qualified to develop their own CMOM programs in accordance with their knowledge and understanding of the collection systems each owns and operates With this in mind, the MWMC has established this framework to guide the partner agencies in the development and implementation of their CMOM Programs. Fundamental CMOM Programs Elements The MWMC s framework for CMOM implementation is based upon ten fundamental elements. Each element must be assessed, communicated, and addressed in the implementation of CMOM for collection system management. The ten fundamental CMOM elements are: 1. Legal Authority Provides and clearly delineates the agency s authority to implement necessary collection system management and control activities to protect infrastructure and regional facilities from SSO s and excessive flows. 2. Financial Capacity Provides sustainable and equitable wastewater rate structures and accounting practices to fund needed programs (including staffing, training, equipment, and materials); assess and track costs; and support budget development and long term financial planning. 3. Periodic Review Ongoing performance assessment and adjustment is an essential and necessary feature of CMOM. This ongoing review and adaptation allows CMOM to stay effective in the face of continually changing system conditions. 4. Sewer System Inspection, Maintenance and Repair/Rehab Program (including flow monitoring) Provides real time understanding of the collection system s condition and performance, implements proactive maintenance activities, allows resource prioritization and scheduling, and identifies necessary rehabilitation projects. 5. Source Control Provides the policies and programs needed to control what comes into the collection system to prevent: SSOs; corrosion and; blockages caused by debris, plastics, roots and/or grease or other materials. 6. Private Lateral Program Private Lateral Programs address rainfall derived inflow and infiltration entering the system from wastewater laterals located on private property and are structured to systematically identify defects and illicit cross connections in the private laterals. Each local agency should evaluate and explore what level of action is appropriate in developing a private lateral program to mitigate inflow to the regional system. 7. Capacity Assessment, Evaluation, and Assurance Provides data management, assessment and modeling to deliver an accurate understanding of collection system responses under the full range of projected operating conditions to identify current and future capacity limitations, and to support infrastructure planning efforts. 8. Emergency Response and Public Notification SSO emergency response plans are required under the NPDES permit and state and federal rules. These plans are also necessary to protect the public health. Such plans should include protocols and identify resource alternatives necessary to quickly and effectively respond to, control, report, and mitigate an SSO event. 9. Long term Asset Management and Planning Long term asset management is a component of CMOM that organizes management of capital infrastructure system components to minimize ATTACHMENT 1 Pages 2 OF 3

6 the total costs (both capital and annual operations and maintenance costs) while ensuring system performance requirements are met. In the case of CMOM, the system performance requirements must satisfy the regulatory requirements at all times and meet customer service expectations. Planning is needed to evaluate future system requirements and adapt asset management as necessary. 10. Regional Communication Requirements Ensures annual CMOM progress assessments are documented and communicated to the MWMC and supports existing annual Inflow and Infiltration Reduction Plan reports currently issued to the Oregon Department of Environmental Quality. These ten fundamental elements form the minimum basis of each partner agencies CMOM program. In addition to this Framework Document, the MWMC Regional CMOM Guidance Document provides detailed descriptions of the fundamental elements and includes discussion of the many factors agencies will need to consider as they develop their individual CMOM programs. ATTACHMENT 1 Pages 3 OF 3

7 City of Eugene CMOM Plan Executive Summary A CMOM (Capacity, Management, Operations, and Maintenance) program provides a starting point for municipalities that operate a wastewater collection system to increase the efficacy of the system using industry-recognized best management practices as compiled by the EPA (Environmental Protection Agency). A CMOM program is not a one-size-fits all method, because every collection system is different. As a result, CMOM programs are tailored to the specific challenges that a collection system faces. The first step in a successful CMOM program is to identify the gaps within a municipalities wastewater collection service. This examination, and the gaps in the service that were identified as a result, will form the foundation of all subsequent CMOM efforts. The EPA s checklist has 204 discrete items that cover all of the best management practices for sewer collection systems: out of those myriad items, the City of Eugene (COE) only identified the following five items that are in need of refinement. It should be noted that upon discovery of these gaps, COE staff immediately set out to rectify the issues. Before those gaps are detailed, it is also important to understand that the gaps found during this examination do not constitute a dire threat to the wastewater collection system s efficacy; rather, the gaps found, and the corresponding recommended corrective actions are for optimizing the City s current excellent wastewater service. Simply put, the COE s wastewater collection system is operated, managed, and maintained in an exemplary fashion, and any corrective actions are small, but necessary improvements. Finally, for the impetus behind CMOM programs the elimination of SSOs the COE has an enviable record of less than one SSO per year per 100 miles of pipe. Further, for the SSO s the City has had in the last five years, there have been no discernible patterns for their occurrence. This is important because it means there is not an activity, type of equipment, or location that is more likely for an SSO, and that City staff learn from each event, and use preventative maintenance techniques to prevent a similar SSO from happening again. Capacity Gaps: The City does not currently have a fully functioning collection system software model. The EPA s CMOM guidelines recommend that municipalities have a collection system software model that can be used to predict the collection system s response under a wide range of current and future flow scenarios. The COE s Maintenance Division is currently developing a wastewater model using the software program Mike Urban, which will fulfill all of the EPA guidelines for capacity requirements. As of May of 2015, PWM has a fully calibrated dry weather flow model, and is moving into wet weather calibration. Management Gaps: The CMOM guide lines recommend that field staff be explicitly trained in how to interact with the public. Currently the COE trains its entire staff to interact with the public, and other City of Eugene staff, via a course called Working Better Together. It is recommended that more ATTACHMENT 2 Page 1 of 3

8 emphasis, or another discrete training, be organized that concentrates on interactions with the public specific to the wastewater collection system. It is important to understand that this corrective action represents a refinement of current practices: the COE has a training program for staff to interact with the public. This recommendation will act to augment the COE s current training program. Operations Gaps: The City of Eugene currently has a comprehensive document that details the procedures for preparedness for any catastrophic emergencies that municipalities could experience; this includes, but is not limited to, earthquakes, fires, floods, and terrorist activity. This document is the Eugene-Springfield Metro Area Lane County Emergency Operations Plan, and the goal of this document is to provide the framework for all of the major emergency response procedures for Lane County, and its largest combined urban area. It should be noted that the COE does have comprehensive emergency procedures that detail routine sanitary sewer overflow procedures, and any other so-called routine emergencies a wastewater collection system may experience. It is recommended that the COE continue with the development of the Eugene-Springfield Metro Area Lane County Emergency Operations Plan in conjunction with Lane County and the City of Springfield. Maintenance Gaps: a. Based upon the CMOM examination, the City of Eugene does an exemplary job of cleaning the wastewater collection system. The City has five vactor trucks that operate year-round cleaning the collection system, with an additional two trucks that are normally assigned to the storm water collection system, but can assist if need dictates. Based upon years of observation, the cleaning schedules for individual lines reflects the needs of the system, and scheduling is updated as field staff sees changes during routine maintenance. On the rare occasion the City finds a blockage, or a near blockage, the COE does not map them in its Maintenance Management System (MMS) Software or its City-wide Geographic Information System (GIS), known as GeoDART. It should be noted that the COE Maintenance Division does record the cleaning of wastewater lines and does record the presence of debris and roots. It is recommended that the COE continue to develop, in-house, a maintenance management system that will assist in mapping these types of incidents when they occur. When this corrective action is completed, in addition to the assistance it will provide the Maintenance Division, it will also help the Engineering Division to identify lines that may need to be repaired or replaced during a capital improvement project. b. The COE Maintenance and Wastewater Divisions do not keep an electronic inventory of parts and supplies used for minor collection system repairs. Currently, replacement parts are ordered based upon periodic visual inspection. It is recommended that the City of Eugene create a ATTACHMENT 2 Page 2 of 3

9 database that tracks inventory for minor equipment. The City of Eugene Public Works Maintenance and Wastewater Divisions have always kept an adequate inventory of equipment, and this action represents an optimization of current practice. ATTACHMENT 2 Page 3 of 3

10 City of Springfield CMOM Plan Executive Summary Introduction Springfield provides wastewater service to 18,496 domestic sewer accounts within a 10,000 acre area. This includes a total population served of 70,091 people consisting of 1,306 commercial, 53 Industrial, 66 public, and 17,071 residential customer accounts. Wastewater from Springfield is combined with wastewater from Eugene and treated in regional facilities owned and operated by the Metropolitan Wastewater Management Commission (MWMC). After treatment, the cleaned water is discharged to the Willamette River in accordance with regulatory requirements described in the National Pollutant Discharge Elimination System (NPDES) permit that is jointly held by Springfield, Eugene, and the MWMC. In addition to water quality limits and treatment requirements, the NPDES permit contains standard federal permit conditions related to Sanitary Sewer Overflows (SSOs) that apply to all portions of the collection system for which the permit holder has ownership and/or operational control. Springfield staff has prepared a Springfield CMOM Plan using the findings from a gap analysis prepared according to EPA guidance documents as well as the Regional CMOM framework document provided by the MWMC. The plan provides the City with an adaptive and comprehensive framework that integrates the various functions of wastewater conveyance system planning, mapping, condition assessment, operations and maintenance, and capital improvements into a single program. CMOM will help the City achieve better prioritization of collection system maintenance and rehabilitation activities, and improve capital project selection and financing. Goals of the City of Springfield s CMOM Plan Protect the public health of the citizens in our service area. Protect water quality and the environment. Eliminate SSOs in the local collection systems as much as feasible. Provide sufficient capacity to convey base and peak flows without sanitary sewer overflows for all parts of the collection system. Reduce the amount of inflow and infiltration entering the system in order to minimize the need for a costly future expansion of the treatment plant. Implement feasible steps to stop and mitigate the impacts of sanitary sewer overflows from any portion of the collection system. Provide timely notification of sanitary sewer overflows from the collection system to persons with reasonable potential for exposure to pollutants from such overflows. Support the MWMC s partnership activities, participate in the regional Wastewater Policy Team, and assist with development and implementation of regional strategies. Ensure that a financial strategy is in place, including appropriate local fee structures, to adequately support needed collection system management functions. Establish a collection system management-planning framework for ongoing improvement and to inform system rehabilitation needs. ATTACHMENT 3 Page 1 of 3

11 Plan Elements System Evaluation and Capacity Assurance This plan element identifies the physical inventory and characteristics of the City of Springfield s wastewater collection system. This element focuses on best management practices to address capacity issues by measuring the City s effectiveness in: Engineering Design, Flow Monitoring and Modeling, CCTV inspections, Smoke and Dye Testing, Hydrogen Sulfide Monitoring and Control, Rehabilitation, and Inflow/Infiltration (I/I) Assessment & Removal. There are two primary findings in this area. First is that the City of Springfield has an extremely low rate of Sanitary Sewer Overflows (SSO s). The rate is less than 1 (0.6) per hundred miles of system per year. This is very favorable performance relative to the mean and average values of the utilities surveyed in the past by the EPA in Regions 4 and 9, and in a survey of 46 systems performed by the California Regional Water Quality Control Board. The second primary finding is the amount of I/I entering the system. Based on a 2013 analysis of available flow monitoring data commissioned by the MWMC, it is estimated that peak flow to the Eugene-Springfield WPCF associated with the 5-year, 24-hour wet-weather design storm is 297 million gallons per day (mgd), which is 7 percent greater than the facility s peak wet weather treatment capacity. The associated wet weather infiltration and inflow is nearly identical for Eugene and Springfield, estimated at approximately 12,000 gallons per acre per day (gpad). These estimates are generally consistent with previous peak flow estimates and infiltration studies that recommended peak flow control, primarily through infiltration and inflow reduction activities, as an ongoing element of peak flow management for each City. Collection System Management This plan element focuses on best management practices for the management of the system and evaluates the City s: management structure, staff training, customer service, data management and reporting system, legal authorities, internal communication, FOG program, and SSO Emergency Response Plan. The primary finding in this area is the need for the City to create legal authorities in the municipal code to address I/I removal from the private portion of the collection system. Collection System Operations This plan element focuses on best management practices for the operation of the system and evaluates the City s: budget for CMOM related activities, the safety program, emergency response and preparedness, system mapping, pump stations, and SSO tracking. The primary finding in this area is that the City has a very lean operation but is meeting the minimum requirements in this area. Collection System Maintenance This plan element focuses on best management practices for the maintenance of the system and evaluates the City s effectives in system cleaning, manhole inspections, equipment and system maintenance, parts inventory, and sewer use ordinances. The primary finding in this area is that the City has a very lean operation but is meeting the minimum requirements in this area. ATTACHMENT 3 Page 2 of 3

12 Plan Implementation Priorities The City of Springfield has identified these key areas as the first focus areas in implementing the plan: Capacity Assessment Design and implement a new flow monitoring strategy to clearly identify I/I locations and prioritize areas for rehabilitation Rehabilitation Identify and prioritize rehabilitation projects in the Capital Improvement Program. Identify project funding and plan for delivering the projects. I/I Assessment and Removal In addition to the flow monitoring strategy and rehabilitation efforts for the publicly owned system, create a strategy and plan for implementing a Private Lateral program in Springfield. Legal authority (LA) Work with our City Council to create municipal code language for a Private Lateral repair program in Springfield. General Create performance metrics in each plan element area and engage in regular cross-disciplinary meetings of key staff to evaluate adaptive management opportunities and monitor plan activities. ATTACHMENT 3 Page 3 of 3