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CMOM + SSOI = Compliance.

James H. Forbes, Jr., P.E. ­ Pipeline Analysis, LLC Mattie A. Engels, EIT ­ Pipeline Analysis, LLC

ABSTRACT Municipalities and utility districts across Texas are faced with increasing regulatory compliance in the area of wastewater collection system Sanitary Sewer Overflows. CMOM or Capacity assurance, Management, Operation and Maintenance is an initiative that was developed by EPA. Although the proposed CMOM rules have been developed, EPA has yet to implement them "officially". Meanwhile in Texas, TCEQ has implemented portions of CMOM in the Sanitary Sewer Overflow Initiative (SSOI). This paper presents the results of case studies to show how a "voluntary CMOM self-audit" fits into the SSOI Plan.

KEY WORDS Sanitary Sewer Overflow Initiative (SSOI), SSO Initiative Plan, Administrative Order, Compliance Order, CMOM Self-Audit, EPA, TCEQ, Regulatory Compliance

INTRODUCTION The USEPA has proposed regulations to address Sanitary Sewer Overflows (SSO's). The proposed regulations will impact how the city manages and maintains its wastewater collection system. A major component of the USEPA's draft SSO rule relates to the Capacity, Management, Operation & Maintenance (CMOM) program. The CMOM program is intended to provide a structured plan for collection system management. The objective is to optimize system performance and develop specific plans for capital improvement and maintenance activities needed to operate, manage, and maintain collection systems and avoid SSO's. Portions of these proposed rules are being implemented thru the Texas Commission on Environmental Quality (TCEQ) Sanitary Sewer Overflow Initiative (SSOI). The SSOI is a voluntary program with considerable interest to those communities experiencing SSO's. Although not currently required by regulation, several cities in Texas have initiated CMOM self-audits to identify where improvements are needed and establish if joining the SSOI would be beneficial. Figure 1 presents how the CMOM self-audit fits into collection system management. 1. Master Plan Wastewater collection system master plans are prepared to plan and prioritize future needs. This "road map" to the future allows the municipality to develop capital improvement programs to 1

ensure the infrastructure to accommodate growth is in place. Master planning efforts look twenty years and more into the future. Depending on jurisdictional boundaries, the master plan may look at ultimate build-out to ensure collection system piping can provide ultimate capacity and project when pipelines will be needed. It is commonplace for master plans to utilize hydraulic modeling of the collection system to simulate current and future system flows. Models calibrated to actual dry and wet weather flows provide a high degree of reliability in predicting needed capacity and line sizes. A major deliverable in the master plan is the capacity analysis of the collection system with recommended timing and sizing of improvements. 2. CMOM-self audit The proposed CMOM regulations require that wastewater utilities: 1) properly manage, operate and maintain all parts of the collection system; 2) provide adequate capacity to convey base and peak flows; 3) take all feasible steps to stop and mitigate the impact of SSOs; 4) provide notification to affected parties in the event of an overflow; and 5) document the CMOM program with performance indicators to gauge results. The CMOM self-audit would be reviewed every year and updated as needed. Portions of the master planning efforts overlap the CMOM audit. For example, the capacity assessment that was completed in the master plan will be identified in the audit. In addition, the flow monitoring undertaken to calibrate a hydraulic model will establish the collection system infiltration/inflow and therefore prioritize areas of the collection system for testing and rehabilitation. If no master planning efforts have been undertaken, the CMOM audit may recommend performing some master planning functions to address capacity assurance issues. The CMOM report will address the following major areas of the Self-Audit: · Engineering Design · Satellite Communities · Sewer Use Ordinances · Organizational Structure · Internal Communications · Budgeting · Training · Safety · Customer Service · Equipment and Collection System Maintenance · Equipment Parts Inventory · Management Information System · System Mapping · Internal CCTV Inspection · Sewer Cleaning · Manhole Inspection and Assessment Pump Stations · · Capacity Assessment · Tracking SSOs · Overflow Emergency Response Plan · Smoke and Dye Testing · Hydrogen Sulfide Monitoring & Control · Infrastructure Security


3. Collection System Renewal (Find-it, Fix-it) Wastewater collection system assets have a useful design life of approximately 75 to 100 years. Whether manholes or pipelines reach their useful life are to a great extent based on the materials of construction, soil condition, construction bedding, hydrogen sulfide concentrations, root intrusion, and sound maintenance practices. Collection system renewal is a continual process of finding system defects, prioritizing them and fixing them. The goal for the collection system manager may be to inspect the collection system on a 10-year cycle. (Note that critical sewers or those assets in flood prone areas may be on an annual cycle of inspection.) A ten year cycle will require inspecting/testing 10% of the collection system annually. The results of the inspection will generate repairs to manholes and mainline sewers. Private sector defects will also be identified requiring enforcement of local codes. Budgeting funds to find and fix system defects is the least cost solution to extend the life of the collection system another 75 to 100 years. Waiting for pipeline or manhole failure will require replacement of the assets which is the most expensive alternative (by several factors). Collections system tools used to "find" defects include flow monitoring (to prioritize areas), manhole/pipe inspections, smoke testing, dye flooding and CCTV inspection. Rehabilitation methods available to extend the life of collection system assets (renewal of assets) include trenchless technologies that minimize the impact to customers. Manhole rehabilitation may include lining, sealing, installing water tight ring and covers, raising buried manholes to grade, replacing vented covers, etc. Mainline sewer rehabilitation may include cured-in-place pipe (CIPP), slip lining and upsizing or pipe replacement by pipe bursting. These "fix-it" technologies are expanding to service laterals which must be addressed by collection system managers. Figure 1 depicts the connection between each process. For example, the capacity analysis performed in the master plan will impact sewer system renewal. Knowing when a particular pipeline will require upsizing will impact the decision to rehabilitate the pipe. It may be more cost effective to defer rehabilitation (yet maintain the pipe) and replace the pipe as part of the capital improvement plan (CIP). Also, the least cost renewal plan may require deferring some rehabilitation until sufficient quantities are identified to reduce unit repair costs. Utilization of term contracts or use of the Buy Board for collection system renewal is gaining favor as it speeds up the process of rehabilitation and fixes unit prices, thus keeping projects within annual budgets.


Figure 1 ­ Wastewater Collection System Management Processes


CMOM SELF AUDIT Audits are by definition normally performed by an outside third party. The primary reason in having third party involvement is to obtain an objective evaluation of the collection system operations and management, and to limit any bias. It is difficult for staff to objectively evaluate and grade their own management of the collection system. It is even more difficult for staff to provide constructive criticism of policy, budget process or other departments. Therefore, the CMOM self audit is normally performed by an outside consultant. Figure 2 presents a summary of the CMOM self audit process. Development of the City's CMOM and Asset Management Program will involve participation of various departments within the City. Key individuals within the City will be identified for subsequent interview. Specialized expertise may be brought in from outside the City to address technical issues that may arise during the audit. Determining where the utility is today and identifying areas where improvements are needed is the primary purpose of the audit. Identifying the key staff to be interviewed is critical to a successful audit. Working with the collection system manager, each area of the audit will have a staff member assigned as the primary contact. For example, questions associated with a fats, oil and grease (FOG) may be directed to the pretreatment supervisor or, for some cities, the health department. Once the list is finalized, the actual interviews will be scheduled and conducted. Based on the interview, other staff members may be identified for follow up questions or clarification. A final report is prepared that summarizing the strengths and weaknesses within the organization. Where deficiencies are noted, a recommendation is presented along with proposed schedule and costs necessary to implement the changes. Figure 3 presents an example summary of findings that address the various processes reviewed during the audit. This summary provides a quick review identifying areas needing improvement.



Figure 3 ­ CMOM Audit Review Example

Operations Review Summary

City of Meridian, Mississippi, Department of Public Works

Rating of Adequacy or Completeness (1-10)

Status of Program Element

Does Not Exist Not Applicable

Program Category, Elements, and Sub-elements








8 8 8



Collection System Policy

Customer Service Regulatory Compliance SSO Policy Regulatory Reporting Managing Assets GIS Mapping Construction Inspection Warrantee Tracking SSES CCTV Cleaning Work Management

6 9 9 9 8 7 10 3 5 9 9 9 8 5 1 7 8 8 9 7 3 9 6 5 9 7 8 8 5


Corrective Maintenance

Priority System Backlog System

Preventive Maintenance

Hydraulic Cleaning FOG Program

Emergency Response Plan


As-built Plans Asset Inventory Sewer System Maps Sewer Design/Construction Inspection Rehabilitation/Replacement for Lines and Manholes Capacity assurance

Technical Support Functions

Information Management Contingency Planning Legal Support

Administrative Support

Human Resources Procurement Spare Parts Financial ­ CIP/Rate Review Public Information

Staff Training

Safety Program Schools/Certification Attendance

8 4



COMMON AUDIT FINDINGS Recently completed Texas CMOM self audits have some common findings. Following are some common observations: Cities performing CMOM audits tend to: 1. be proactive with regard to regulations and very knowledgeable with regard to the current status of regulatory programs 2. have treatment plants 3. good safety program 4. have satellite systems 5. have updated master plans 6. have a CIP program 7. have GIS mapping capability with all assets numbered 8. use trenchless technologies where applicable 9. be optimistic about the findings 10. show interest in the TCEQ SSOI program Common findings of the audit include: 1. Inadequate private sector defect repairs (code enforcement) 2. Preventive maintenance cleaning is not being undertaken due to insufficient equipment and crews 3. The Sewer Use Ordinance (SUO) needs to be updated 4. Inadequate documentation of the Fats, Oil and Grease (FOG) policy 5. Inadequate grease trap design criteria and inspection program (address apartments) 6. Lack of GIS attribute data 7. Inadequate tracking and inspection of construction warrantees 8. No prioritized inspection/testing program on an annual basis 9. Poor documentation of O&M processes (pump stations, SCADA, etc) 10. Lack written safety policy and procedures and documentation of individual training 11. Not reviewing or adhering to the provisions within satellite agreements/contracts 12. Water Department staffing, as it relates to the collection system, is currently only keeping up with demands 13. During design, the impact of new develop on the downstream reaches of the system are not fully assessed 14. Disconnects between departments (particularly engineering and operations) common (design reviews, inspection, acceptance, warrantee monitoring, construction materials and specifications, mapping updates, etc.) 15. Inadequate documentation of the Emergency Response Plan for SSO's 16. Lack of methodology for quantifying SSO's


TCEQ SSO INITIATIVE The Texas Commission on Environmental Quality (TCEQ) has developed a voluntary SSO Initiative to assist municipalities with addressing SSO's that might escalate to such a degree as to cause a negative impact on human health and safety or the environment. Participation in this outreach initiative is entirely voluntary. The CMOM audit reviews the current status of SSO's within the collection system, how they are being quantified and trends. Based on this review, the audit may include a draft SSO Initiative Plan and recommendation to join the TCEQ initiative. The SSO Initiative closely follows many aspects of the CMOM with the intent of optimizing the collection system performance and minimizing sanitary sewer overflows. Items addressed in a SSOI Plan include: A. Establish Causes of SSO's B. Review Sewer Overflow Emergency Response Plan C. Pipeline Capacity Assurance D. Provisions for SSO Initiative Program E. Infiltration/Inflow Reduction Program F. Sources of Funding G. Project Timeline H. Program Effectiveness (Performance Indicators)

The TCEQ program can provide Texas municipalities with up to ten years to fully address SSO's without the threat of regulatory penalties (except under extreme cases). This program is voluntary and will require the municipality to enter into an agreement with TCEQ that stipulates schedules that must be met. The plan and schedule are developed by the municipality and addresses their unique collection system needs.

CONCLUSION The CMOM self audit is a tool that collection system managers can use to gauge where limited resources need to be allocated. The findings of an audit may not always be surprising, but they do provide an unbiased review and priority ranking of where the utility can improve. Benefits of the audit include reallocation of funds to fill higher priority gaps identified in the audit, benchmark where the utility is today and how to measure future performance, improve communications between departments, provides the third party evidence to justify budget items to council for management and provide a document that can be reviewed and updated annually.


CORRESPONDING AUTHORS James H. Forbes, Jr., P.E. [email protected] Mattie Engels, EIT [email protected] Pipeline Analysis, LLC 13661 Jupiter Road, Suite 307 Dallas, Texas 75238 800-637-0164



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