1. Fox Valley OperatorsAssociationCMOM Capacity Management Capacity ManagementOperationMaintenance January 2011 C apacity M anagement O peration & M aintenance

2. Fox Valley OperatorsAssociationCMOM Capacity Management Capacity ManagementOperationMaintenance January 2011 Background  Late 1800’s Germ Theory by Koch & Pasteur  1900 Beginning of the Profession Water Quality linked to Health Risks Water Quality linked to Health Risks Protection of drinking water sources Protection of drinking water sources Major Cities begin development of sanitation Major Cities begin development of sanitation Chicago’s Sanitary and Ship Canal Chicago’s Sanitary and Ship Canal  1910 – 20’s Treatment processes developed Cities start to boom Cities start to boom Higher density creates need for treatment Higher density creates need for treatment Constructing sedimentation tanks Constructing sedimentation tanks “get the big stuff out” “get the big stuff out”  1930 – 40’s Treatment advances More growth – more pollution More growth – more pollution WPA projects create funding source for POTWs WPA projects create funding source for POTWs But Implementation of treatment not uniform But Implementation of treatment not uniform

3. Fox Valley OperatorsAssociationCMOM Capacity Management Capacity ManagementOperationMaintenance January 2011 Background  Federal Water Pollution Control Act of 1948 First major U.S. law to address water pollution First major U.S. law to address water pollution Enforcement limited to interstate waterways Enforcement limited to interstate waterways Each State had its own standards Each State had its own standards Planning was not uniform Planning was not uniform Collection system designs varied (combined/ separated) Collection system designs varied (combined/ separated) Overflows were common Overflows were common Level of treatment varied Level of treatment varied Water Quality suffered Water Quality suffered  1960’s the environment becomes a hot issue Industrial waste dischargers unchecked Industrial waste dischargers unchecked Wildlife and Aquatic Life were impacted Wildlife and Aquatic Life were impacted Pollution was a common problem Pollution was a common problem America wasn’t so beautiful America wasn’t so beautiful Fox Valley Operators Association was founded Fox Valley Operators Association was founded

4. Fox Valley OperatorsAssociationCMOM Capacity Management Capacity ManagementOperationMaintenance January 2011 Background  Federal Water Pollution Control Amendments of 1972 – (CWA of 1972) Declared most waterways “Waters of the States” Declared most waterways “Waters of the States” Expanded and strengthened the previous legislation Expanded and strengthened the previous legislation Established US Environmental Protection Agency Established US Environmental Protection Agency Tasked USEPA with evaluating situation Tasked USEPA with evaluating situation Gave USEPA the authority to regulate POTW’s Gave USEPA the authority to regulate POTW’s Est. the framework for Water Quality Standards Est. the framework for Water Quality Standards Established the NPDES Permit System Established the NPDES Permit System Established technology based limits Established technology based limits Secondary Treatment Standards Secondary Treatment Standards

5. Fox Valley OperatorsAssociationCMOM Capacity Management Capacity ManagementOperationMaintenance January 2011 Background  Clean Water Act of 1977 Amended the 1972 legislation Amended the 1972 legislation Established Water Quality Standards Established Water Quality Standards Established Federal Grant Program Established Federal Grant Program Facility Plan Amendment – planning and treatment Facility Plan Amendment – planning and treatment Sanitary Sewer Evaluation Surveys – collection systems Sanitary Sewer Evaluation Surveys – collection systems  Sanitary Sewer Evaluation Survey Manhole Inspection Manhole Inspection Flow Monitoring Flow Monitoring Documentation of defects Documentation of defects Cost effective analysis of alternatives Cost effective analysis of alternatives Sewer Separation Sewer Separation Sewer Rehabilitation Sewer Rehabilitation Excess Flow Facilities Excess Flow Facilities CSO Treatment Facilities CSO Treatment Facilities

6. Fox Valley OperatorsAssociationCMOM Capacity Management Capacity ManagementOperationMaintenance January 2011 Background  Grant Program Provided federal funds for implementation Provided federal funds for implementation Direct Sanitary Sewer Overflows were eliminated Direct Sanitary Sewer Overflows were eliminated Collection systems were rehabilitated Collection systems were rehabilitated Infiltration and Inflow was reduced Infiltration and Inflow was reduced Combined Systems were often separated Combined Systems were often separated Excess Flow and CSO Treatment Facilities were constructed Excess Flow and CSO Treatment Facilities were constructed

7. Fox Valley OperatorsAssociationCMOM Capacity Management Capacity ManagementOperationMaintenance January 2011 Background  Water Quality Act of 1987 Amended Water Quality Standards and procedures Amended Water Quality Standards and procedures Added regulation of biosolids Added regulation of biosolids MS-4 permit system for storm water MS-4 permit system for storm water Increased regulation of non-point discharges Increased regulation of non-point discharges Eliminated Grant Funding Eliminated Grant Funding Established Revolving Loan Fund Established Revolving Loan Fund  Results More stringent Water Quality Standards More stringent Water Quality Standards POTW’s forced to focus on treatment technology POTW’s forced to focus on treatment technology Unfunded mandates equated to increase user rates Unfunded mandates equated to increase user rates Investment into collection system rehab slowed Investment into collection system rehab slowed

8. Fox Valley OperatorsAssociationCMOM Capacity Management Capacity ManagementOperationMaintenance January 2011 The Last Twenty Years  Discharges that do not meet WQS are in violation of the Clean Water Act. CSO’s & SSO’s are a violations of the CWA CSO’s & SSO’s are a violations of the CWA  Remaining CSO/SSO’s were made top priority. Regulators pursued enforcement through the through NPDES permits process. Regulators pursued enforcement through the through NPDES permits process. POTW’s negotiated Compliance Agreements POTW’s negotiated Compliance Agreements POTW’s developed and implemented “Long Term Control Plans” POTW’s developed and implemented “Long Term Control Plans”

9. Fox Valley OperatorsAssociationCMOM Capacity Management Capacity ManagementOperationMaintenance January 2011 Last Twenty Years  Focus is shifting to communities with separate sanitary sewer systems Sanitary Sewer bypasses have been eliminated Sanitary Sewer bypasses have been eliminated Basement back-ups & sewer overflows still occur Basement back-ups & sewer overflows still occur The industry starting looking at why? The industry starting looking at why? Partly because SSES programs were static Partly because SSES programs were static Partly because Funding wasn’t available Partly because Funding wasn’t available Partly because Political will to raise rates didn’t exist Partly because Political will to raise rates didn’t exist Partly because few measured the successes Partly because few measured the successes Therefore we could not show cause and effect Therefore we could not show cause and effect

10. Fox Valley OperatorsAssociationCMOM Capacity Management Capacity ManagementOperationMaintenance January 2011 Last Twenty Years  Water Professionals started seeking success I/I due to deterioration of system I/I due to deterioration of system Unsuccessful SSES Projects Unsuccessful SSES Projects Reduction of I/I is not a one time project Reduction of I/I is not a one time project POTW’s with annual programs were successful POTW’s with annual programs were successful

11. Fox Valley OperatorsAssociationCMOM Capacity Management Capacity ManagementOperationMaintenance January 2011 CMOM  New Provision of the Clean Water Act Regulates Sanitary Sewer Overflows Regulates Sanitary Sewer Overflows Reduce health/environmental risks Reduce health/environmental risks Improve the performance of treatment facilities Improve the performance of treatment facilities Protect the nation’s collection systems Protect the nation’s collection systems Reduce equipment and operational failures Reduce equipment and operational failures Extend the life of the treatment equipment Extend the life of the treatment equipment

12. Fox Valley OperatorsAssociationCMOM Capacity Management Capacity ManagementOperationMaintenance January 2011 CMOM  Proposed Regulation prohibits any discharge prior to the WWTP Provides consideration for severe natural causes Provides consideration for severe natural causes POTW must report all SSO’s within 10 ten days POTW must report all SSO’s within 10 ten days Demonstrate that cause was beyond control of POTW Demonstrate that cause was beyond control of POTW POTW must take reasonable steps to stop and mitigate POTW must take reasonable steps to stop and mitigate Consequences for failure to comply with CWA Consequences for failure to comply with CWA Consent Agreements Consent Agreements Administrative Orders Administrative Orders Fines both Criminal and Civil Fines both Criminal and Civil

13. Fox Valley OperatorsAssociationCMOM Capacity Management Capacity ManagementOperationMaintenance January 2011 CMOM  USEPA proposes CMOM programs as a strategy to eliminate SSO’s Capacity Management, Operation and Maintenance Capacity Management, Operation and Maintenance Rulemaking not finalized Rulemaking not finalized Several Regions implementing in anticipation Several Regions implementing in anticipation

14. Fox Valley OperatorsAssociationCMOM Capacity Management Capacity ManagementOperationMaintenance January 2011 CMOM  Regulatory Issues IEPA has issued NPDES permits requiring implementation of a CMOM program IEPA has issued NPDES permits requiring implementation of a CMOM program Primarily to POTW’s that report chronic basement back- ups or SSO’s from surcharged sewers. Primarily to POTW’s that report chronic basement back- ups or SSO’s from surcharged sewers. MWRDGC is implementing CMOM requirements for Satellite systems to demonstrate compliance MWRDGC is implementing CMOM requirements for Satellite systems to demonstrate compliance

15. Fox Valley OperatorsAssociationCMOM Capacity Management Capacity ManagementOperationMaintenance January 2011 CMOM  What now? Use this Window of Opportunity Use this Window of Opportunity Get ready for CMOM Get ready for CMOM Set up program voluntarily Set up program voluntarily Document progress Document progress Avoid Compliance Agreement Avoid Compliance Agreement  CMOM Requires Provide capacity to convey base and peak flows Provide capacity to convey base and peak flows Proper management, operation and maintenance of all parts of the collection system Proper management, operation and maintenance of all parts of the collection system Interceptors Interceptors Sewers Sewers Satellite Systems Satellite Systems Private Laterals?????? Private Laterals??????

16. Fox Valley OperatorsAssociationCMOM Capacity Management Capacity ManagementOperationMaintenance January 2011 CMOM  CMOM Requires (cont.) Take steps to stop and mitigate SSO’s Take steps to stop and mitigate SSO’s Provide notification to public and regulatory officials Provide notification to public and regulatory officials Develop written summary of CMOM Program Develop written summary of CMOM Program Show staff responsibilities and chain of command Show staff responsibilities and chain of command Documentation of capacity analysis Documentation of capacity analysis Documentation of sewer maintenance program Documentation of sewer maintenance program Documentation of SSO response plan Documentation of SSO response plan Documentation of improvements within system Documentation of improvements within system

17. Fox Valley OperatorsAssociationCMOM Capacity Management Capacity ManagementOperationMaintenance January 2011 CMOM  CMOM Requires (cont.) Capacity Capacity Analysis of collection system Analysis of collection system o Flow Monitoring and modeling o Implementation of recommended improvements Management Management Documentation Documentation Infiltration and Inflow Reduction Programs Infiltration and Inflow Reduction Programs Implement current design and construction standards Implement current design and construction standards Inspection of sewer installation Inspection of sewer installation Training of Operational Staff Training of Operational Staff Management of Pre-Treatment Programs Management of Pre-Treatment Programs Management of Satellite Systems Management of Satellite Systems Mapping & GIS Mapping & GIS Trending and History Records Trending and History Records Document Non-Compliance Events Document Non-Compliance Events

18. Fox Valley OperatorsAssociationCMOM Capacity Management Capacity ManagementOperationMaintenance January 2011 CMOM  CMOM Requires (cont.) Operation Operation Flow Monitoring Flow Monitoring Implement SSO Response Plan Implement SSO Response Plan o Monitor areas subject to Overflows during events o Investigate SSO’s o Notification of Public o Notification of Public Health Officials o Notification of Illinois EPA Maintenance Maintenance Manhole Inspections Manhole Inspections Mapping Mapping Sewer Cleaning and Televising Sewer Cleaning and Televising o Root Control o Identify Structural Defects o Identify Sources of I/I

19. Fox Valley OperatorsAssociationCMOM Capacity Management Capacity ManagementOperationMaintenance January 2011 CMOM  Where do we start Gap Analysis Gap Analysis Review of existing programs Review of existing programs Identify elements which need enhancement or development Identify elements which need enhancement or development o Interview staff o Field Investigations o Review of Records Develop program Develop program Budgets Budgets Education of Public Officials Education of Public Officials Develop Documentation Develop Documentation

20. Fox Valley OperatorsAssociationCMOM Capacity Management Capacity ManagementOperationMaintenance January 2011 Discussion