Consent Decree Semi Annual Report_March 2012Masterpiece on the Mississippi
TO: The Honorable Mayor and City Council Members
FROM: Michael C. Van Milligen, City Manager
SUBJECT: Consent Decree Semiannual Report
DATE: March 12, 2012
Dubuque
bierd
All-America City
1
2007
City Engineer Gus Psihoyos is submitting the EPA Consent Decree March 5, 2012,
Semiannual Report.
Michael C. Van Milligen
MCVM:sv
Attachment
cc: Barry Lindahl, City Attorney
Cindy Steinhauser, Assistant City Manager
Gus Psihoyos, City Engineer
THE CITY OF
Dui
Masterpiece on the Mississippi
TO Mike Van Milligen, City Manager
FROM Gus Psihoyos, City Engineer
DATE March8,2012
SUBJECT Consent Decree Semiannual Report
Dubuque
band
All- America City
'I 1 1 I'
2007
INTRODUCTION
The purpose of this memo is to seek approval to submit the March 5, 2012 Semiannual Reportto the agencies stated in the Consent
Decree
BACKGROUND
The City of Dubuque, Iowa is under a Consent Decree according to Case 2 11- cv- 01001 -EJM, United States of America and the
State of Iowa v the City of Dubuque, IA [N D Iowa), Civil Action Number 2008V00041, DOJ Case Number 90 -5 -1 -1 -09339 effective
June 27, 2011 The purpose of this report is to satisfy Section VIII, Paragraph 25 of the Consent Decree, which requires the City to
submit a semiannual report by March 31, 2012
DISCUSSION
The purpose of this semiannual report is to satisfy Section VIII, Paragraph 25 of the Consent Decree Paragraph 25 requires the City
to submit semiannual reports by March 31 and September 30 after the Effective Date (June 27, 2011) The report includes summary
information regarding events and activities performed in the prior six months Therefore, the "reporting period" refers to the time
between September 1, 2011 and including February 29, 2012
RECOMMENDATION
I recommend that the City Council authorize the City Managerto certify the March 5, 2012 Semiannual Report
PROJECT COST- BUDGET IMPACT
The recommended actions do not impact the City's budget
ACTION TO BE TAKEN
I request authorization for the Engineering Department to submit the March 5, 2012 Semiannual Report to the agencies stated in the
Consent Decree
Prepared by
Todd Shoemaker, Environmental Engineer
cc
Barry Lindahl, City Attorney
Don Vogt, Public Works Director
John Klostermann, Street &Sewer Maintenance Supervisor
Jonathan Brown, Water Plant Manager
Steve Brown, Project Manager
Deron Muehring, Civil Engineer
Todd Shoemaker, Environmental Engineer
Prepared for:
UNITED STATES
ENVIRONMENTAL
PROTECTION AGENCY,
UNITED STATES
DEPARTMENT OF JUSTICE
AND
IOWA
DEPARTMENT OF
NATURAL RESOURCES
Prepared by:
CITY OF DUBUQUE, IA
50 W 13th Street
Dubuque, IA 52001
Consent Decree
Semiannual Report
March 31, 2012
Consent Decree No. 2:11 -cv- 01011 -EJM
March 5, 2012
Table of Contents
1.0 CERTIFICATION 1 -1
2.0 INTRODUCTION 2 -1
2.1 Background 2 -1
2.2 Purpose 2 -1
2.3 Report Summary 2 -1
3.0 SANITARY SEWER OVERFLOWS 3 -1
3.1 Sanitary Sewer Overflow Record 3 -1
3.2 SSO's Effect on Public Health and Water Quality 3 -1
3.3 Measures Enacted to Minimize Duration and Impact 3 -1
3.4 Measures Enacted to Stop the Overflow Event 3 -1
3.5 Measures Enacted to Prevent Another Recurrance 3 -1
3.6 Capturing Key Way Overflows 3 -1
3.7 Warning Sign Postings 3 -3
4.0 WATER & RESOURCE RECOVERY CENTER CONSTRUCTION UPGRADE. 4 -1
4.1 Project Planning 4 -1
4.2 Current Project Status 4 -1
4.3 Biosolid Accumulation Prevention at the W &RRC 4 -2
5.0 NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM (NPDES) 5 -1
5.1 Summary of all NPDES Permit Requirement Information 5 -1
5.2 NPDES Violations at the WRRC During The Reporting Period 5 -1
5.2.1 NPDES Violation(s) Log 5 -1
5.2.2 Cause of NPDES Violations 5 -1
6.0 INFLOW & INFILTRATION REDUCTION PROGRAM 6 -1
6.1 Background 6 -1
6.2 Flow Metering 6 -1
6.3 Source Investigations 6 -1
6.3.1 Private Property Inspections 6 -1
6.3.2 Dye Testing 6 -2
6.3.3 Smoke Testing 6 -2
6.3.4 Manholes 6 -3
6.3.5 Sanitary Sewer 6 -3
6.4 Corrective Action Plan 6 -3
6.5 Implementation of Corrective Action Plan 6 -3
i
7.0 CMOM UPDATE 7 -1
7.1 The Clv1Olv1 Program 7 -1
7.2 C1v1O1v1Implementation 7 -1
8.0 ASSESSMENTS AND ENGINEERING ANALYSES 8 -1
9.0 OTHER RELATED ACTIVITIES 9 -1
TABLES
Table 2 -1. Organization of information required by the Consent Decree. 2 -2
Table 3 -1. Sanitary sewer overflows during the reporting period. 3 -2
Table 3 -2. Warning sign posting locations. 3 -3
Table 4 -1. Significant deadlines for the Water & Resource Recovery Center. 4 -1
Table 5 -1. Monthly operating reports submitted during the reporting period. 5 -1
FIGURES
Figure 6 -1. Map of priority sewersheds for I &I investigation 6 -2
APPENDICES
Appendix A: Proposed Sewershed 7. 5. and 10 Flow Meter Locations
ii
1.0 Certification
I certify under penalty of law that this document and all attachments were prepared under my
direction or supervision in accordance with a system designed to assure that qualified personnel
properly gather and evaluate the information submitted. Based on my directions and my inquiry
of the person or person who manage the system, or those persons directly responsible for
gathering the information, the information submitted is, to the best of my knowledge and belief,
true, accurate, and complete. I am aware that there are significant penalties for submitting false
information, including the possibility of fine and imprisonment for knowing violations.
Michael C. Van Milligen
City Manager
2.0 Introduction
2.1 BACKGROUND
The City of Dubuque, Iowa is under a Consent Decree according to Case 2:11 -cv- 01001 -EJM,
United States of America and the State of Iowa v. the City of Dubuque, IA (N.D. Iowa), Civil
Action Number 2008V00041, DOJ Case Number 90- 5 -1 -1- 09339.
The Consent Decree became effective on June 27, 2011 and requires the City to submit
semiannual reports to the Department of Justice (DOJ), Environmental Protection Agency (EPA)
and Iowa Department of Natural Resources (DNR).
2.2 PURPOSE
The purpose of this report is to satisfy Section VIII, Paragraph 25 of the Consent Decree.
Paragraph 25 requires the City to submit semiannual reports on March 31 and September 30 after
the Effective Date (June 27, 2011). The report includes summary information regarding events
and activities performed in the prior six months. Therefore, the "reporting period" shall refer to
the time between September 1, 2011 and February 29, 2012.
2.3 REPORT SUMMARY
Paragraph 25 of the Consent Decree requires the semiannual reports to include specific
information as well as a summary of the status and progress of all projects and programs required
by Sections V and VI of the Consent Decree. Table 2 -1 lists how the required information is
organized in this report.
Table 2 -1. Orsanization of information required by the Consent Decree.
Consent Decree
Paragraph
Summary of Requirement
Report Section
25(a)i
Sanitary Sewer Overflow (SSO) locations
3.1
25(a)ii
SSO duration of flows
Table 3 -1
25(a)iii
SSO estimated flow volume
Table 3 -1
25(a)iv
Waterbody downstream of SSO
Table 3 -1
25(a)v
Suspected cause of SSO
Table 3 -1
25(a)vi
SSO effect on public health and water quality
3.2
25(a)vii
Measures to minimize SSO
3.3
25(a)viii
'Measures to stop SSO
3.4
25(a)ix
Measures to prevent recurrence of SSO and
milestones
3.5
25(b)i
Construction upgrades
4.0
25(b)ii
NPDES permit summary
5.1
25(b)iii
NPDES permit violations during reporting
period
5.2
8
Assessments and engineering analyses
8.0
9
Disposal ofbiosolids at WPCP
4.3
10(a)
Capture of overflow from Key Way Drive
manhole
3.6
10(b)
Posting of warning signs at SSO locations
3.7
11
Construction upgrade to WPCP
4.2
12(a)
North Fork Catfish Creek interceptor placed into
service
Reported in 9/30/11
Semiannual Report
12(b)
I &I flow metering
6.2
12(e)
Flow meters installed in first sewershed during
2010
Reported in 9/30/11
Semiannual Report
12(d)
I &I source identification
6.3
12(e)
I &I corrective action plan
6.4
12(f)
Implement I &I corrective actions
6.5
13(a)
Collection System Management. Operation, and
'Maintenance plan (CMOM)
7.0
13(b)
Implement CMOM
7.2
14
Certify legal authority
Completed upon signing
of Consent Decree
15
Certify that Section V of Consent Decree has
been completed and placed into service
To be completed by June
30. 2016
16
Demonstrate all SSO and by- passes have been
eliminated
To be completed by June
30. 2017
17
If SSO or by -pass occurs, submit Remedial Plan
and Schedule
Only applicable after
June 30, 2017
18
If SSO or by -pass occurs due to O &M, submit
Remedial Plan and Schedule
Only applicable after
June 30, 2017
2 -2
3.0 Sanitary Sewer Overflows
3.1 SANITARY SEWER OVERFLOW RECORD
Eleven (11) sanitary sewer overflows (SSO, Table 3 -1) occurred in the City of Dubuque during
the reporting period.
3.2 SSO'S EFFECT ON PUBLIC HEALTH AND WATER QUALITY
No effects on public health were reported. Visual inspection at the downstream waterbody (prior
to discharge to the Mississippi River) showed no sign of putrescent, unsightly or harmful bottom
deposits; oil, scum and floating debris; unsightly color or turbidity; or offensive odors.
3.3 MEASURES ENACTED TO MINIMIZE DURATION AND IMPACT
The City minimized the duration and impact of the SSOs by capturing untreated wastewater and
transporting it to the Water and Resources Recovery Center or by setting up a pump and re-
routing the flow to a downstream sanitary sewer manhole.
3.4 MEASURES ENACTED TO STOP THE OVERFLOW EVENT
For S SO's #3 and #4, the City shut off the lift station pumps and untreated wastewater was
transported to the Water & Resources Recovery Center by tankers. Other overflows were
stopped by removing the blockage or by setting up a pump and re- routing the flow to a
downstream sanitary sewer manhole.
3.5 MEASURES ENACTED TO PREVENT ANOTHER RECURRANCE
Increased maintenance will be performed on lines where debris was the cause of the blockage.
Increased maintenance along with chemical root foaming will be used on the lines where roots
were the cause of the blockage. Following the CMOM, the City continues to implement the Fats,
Oils, and Grease (FOG) ordinance to prevent grease- related overflows.
3.6 CAPTURING KEY WAY OVERFLOWS
Paragraph 10 of the Consent Decree requires the City to capture all overflows from the manhole
located on Key Way Drive between 3500 Keymer Drive and 3507 Keystone Drive. An SSO did
not occur at this location during the reporting period, so it was not necessary to capture any
overflows.
Table 3 -1. Sanitary sewer overflows during the reporting period.
SSO #
Sewer-
shed
Street
Address
Start
Date
End
Date
Start
Time
End Time
Overflow
Volume
Downstream
Waterbodv
Suspected
Cause(s)
1
7
644 Lowell
Street
9/19/11
9/19/11
11:00 a.m
11:10 a.m.
25
Mississippi
River
Defect in the pipe
2
15
Mar Jo Hills Rd
Discover
Date
9/26/12
9/26/11
Unknown
4:00 p.m.
100
Catfish Creek
Bank failure due to
heavy rain event on
7/28/2011
3
20
925 Kerper Blvd
10/4/11
10/4/11
10:30 a.m.
11:15 a.m.
1,000
Mississippi
River
Force Main Break
4
20
509 E 7th St
10/4/11
10/4/11
10:30 a.m.
11:15 a.m.
1,000
Mississippi
River
Force Main Break
5
14
2700 Dodge St
Discover
Date
12/9/11
12/9/11
Unknown
5:00 p.m.
200
Catfish Creek
Grease
6
8
1855 Greyhound
Park Road
1/25/12
1/25/12
2:00 p.m.
3:00 p.m.
200
Mississippi
River
Grease
7
14
290 Bradley
Street on
Henderson Street
2/4/12
2/4/12
10:00 a.m.
10:30 a.m.
100
Mississippi
River
Force Main Break
8
20
820 Mt Loretta
Avenue
Discover
Date
2/14/12
2/14/12
Unknown
3:00 p.m.
50
Mississippi
River
9*
8
2460 Lincoln
Avenue
1/10/12
1/10/12
8:00 p.m.
10:00 p.m.
20
N/A
Roots
10*
10
1990 Amelia
Drive
1/21/12
1/21/12
2:15 p.m.
3:00 p.m.
20
N/A
Debris
11*
1
3274 Kensington
Place g
1/31/12
1/31/12
5:45 p.m.
6:00 p.m.
5
N/A
Valve closed by
mistake
* Basement backup
3 -2
3.7 WARNING SIGN POSTINGS
Paragraph 10 of the Consent Decree requires that the City post a warning sign at all SSO sites for
at least 6 months after completion of the site cleanup. unless IDNR decides that the sign may be
posted for a shorter period of time or not at all. Table 3 -2 lists the current locations where signs
are posted. (Postings are not required for basement backups.)
Table 3 -2. Warning sign posting locations.
SSO #
Location
Description
1
644 Lowell Street
Along north curb
2
Mar Jo Hills Road
Under the highway overpass along Mar Jo Hills Road
3
925 Kerper Boulevard
Along 9th and 11th Streets and at the storm sewer outlet at
12th Street
4
509 E 7th Street
At the 8th Street storm sewer outlet
5
2700 Dodge Street
At the manhole edge of parking lot
6
1855 Greyhound Park Road
At storm sewer outlet along Greyhound Park Road
7
290 Bradley Street
On Henderson Street at Bradley Street
8
820 Nil. Loretta Avenue
At manhole between Mt. Loretta and Southern Avenues
3 -3
4.0 Water & Resource Recovery Center
Construction Upgrade
4.1 PROJECT PLANNING
During its Fiscal Year 2006 goal setting process, the City Council listed the Water Pollution
Control Plant (WPCP) as one of its high priorities. City staff subsequently applied for a State
Revolving Fund (SRF) planning and design loan during the summer of 2006, and plant upgrades
were placed on the DNR Intended Use Plan schedule. Following public hearings and bidding
requirements, the Facility Plan was developed and approved by DNR. The facility's name was
also changed to the Water & Resource Recovery Center (W &RRC).
In October 2008, the team of Strand Associates /IIW Engineers was approved by the City Council
to proceed with the design of the W &RRC upgrades. The NPDES permit was issued by DNR
staff on April 1, 2010, and the plant construction permit was signed by DNR staff on April 5,
2010.
Following public bidding requirements, the City Council approved a contract, and the notice to
proceed was issued August 19, 2010. Table Table 4 -1 lists significant deadlines for the project.
Table 4 -1. Sienificant deadlines for the Water & Resource Recovery Center.
Deadline
Target Date
Digester Startup
8/24/2012
Excess Flow Equalization
6/20/2012
Sludge Processing Startup
12/12/2012
Aeration Tank Completion
6/04/2013
Final Clarifiers
8/15/2013
Substantial Completion
9/9/2013
Final Completion
2/14/2014
4.2 CURRENT PROJECT STATUS
On July 11, 2011 at approximately 6:10 A.M., a thunderstorm with winds of approximately 74
mph caused damage to two of the four digesters under construction. On July 28, 2011, the City
received more than 14 inches of rain in approximately twelve hours which caused considerable
damage to the W &RRC construction site. The damage caused by each event and the City's
response were documented in separate reports to the EPA, DOJ, and DNR dated July 15, 2011
and August 4, 2011.
The City had estimated a project delay of approximately three to four months beyond the final
4 -1
completion date given of October 1, 2013. The City has since granted a 120 working day
extension to the two major milestones of digester startup and sludge processing startup. The City
and its general contractor are working out details of a revised project completion schedule
required by the weather related delays. Factoring in the delays, the City will still meet the startup
deadline (April 26. 2014) as prescribed in the Consent Decree barring any further major
uncontrollable delays.
Through February 29. 2012, the project is in its 18th month of constriction and work has been
started on all aspects of the project. At this point. City staff estimates the project is close to 50 °0
complete with an expenditure of approximately $31.000.000 to date. The ultraviolet disinfection
system was started in March 2011 and continues to be operational. Work continues on the
digesters and sludge processing complex. The construction of the fourth primary clarifier
concrete work is completed with the mechanisms beginning to be installed. The reconstruction of
primary clarifier number 1 is complete with a few minor mechanical details to finish prior to
starting the clarifier. When this clarifier is on -line, work will begin on the reconstruction of the
remaining clarifiers. A minimum of two clarifiers will remain in service during construction. In
addition to the digester structures, work is progressing on the piping associated with the digester
operation along with the installation of the many pumps and motors required for the process. A
bio- solids handling contract has been negotiated with Nutri -Ject Systems of Hudson. Iowa and
will be on the March 19, 2012 City Council agenda for approval.
The laboratory addition of the Administration /Laboratory Building is now estimated to be
completed in early to mid -April 2012. Upon completion of the laboratory addition, the existing
building will be totally renovated and placed into service. The Administration /Laboratory
Building will be a highly energy efficient building using plant effluent to meet heating and
cooling needs. The entire structure is highly insulated and will use a minimum of energy for
lighting, heating and cooling.
-4.3 BIOSOLID ACCUMIULATION PREVENTION AT THE W &RRC
The City operates the north incinerator and one of two centrifuges to maintain proper sludge
blanket levels in the final clarifiers. In the event that the north incinerator must be shut down for
longer than one week, the City would continue to operate the centrifuges and dispose of the
sludge at the Dubuque Area Metropolitan Sanitary Landfill. Based on past history, a worst -case
complete shutdown, repair and startup of the incinerator can take place in four to six weeks.
The supplier of new centrifuges for the plant upgrade is the same firm that has performed major
maintenance on the existing centrifuges. This firm has informed W &RRC staff that they would
be available to assist should one or both of the operating centrifuges have a major breakdown. At
the point one of the centrifuges needs to be removed to proceed with that phase of construction,
all critical parts from the removed centrifuge will remain on the site in order to facilitate a rapid
repair of the existing centrifuge and return the plant to full operating conditions.
Storage space for sludge will remain a challenge until portions of the new plant are brought
online. When sections of the reconstructed plant are brought into service, the City will be able to
use these areas to assist in W &RRC sludge management.
4 -2
5.0 National Pollutant Discharge Elimination
System (NPDES)
5.1 SUMMARY OF ALL NPDES PERMIT REQUIREMENT INFORMATION
NPDES Monthly Operating Reports (MOR) for the City of Dubuque W &RRC were submitted to
IDNR on the dates listed in Table 5 -1:
Table 5 -1. Monthly oneratin6 reports submitted durin the renortin6 period.
Report
Date Submitted
August 2011
9/12/2011
September 2011
10/10/2011
October 2011
11/14/2011
November 2011
12/14/2011
December 2011
1/12/2012
January 2012
2/13/2012
February 2012
To be submitted
approximately 3/6/2012
5.2 NPDES VIOLATIONS AT THE WRRC DURING THE REPORTING PERIOD
5.2.1 NPDES Violation(s) Log
The City of Dubuque W &RRC had no permit violations during the reporting period.
5.2.2 Cause of NPDES Violations
There were no NPDES violations for the reporting period.
6.0 Inflow & Infiltration Reduction Program
6.1 BACKGROUND
Prior to the Consent Decree date of lodging, the City experienced several discharges of untreated
or partially treated wastewater. These events were caused by sharp increases in flow within the
sanitary sewer system during and immediately after a rainstorm. To better locate the sources of
this issue, the City placed flow meters throughout the city. Depending on location, the meters
measured the flow of water from each sewershed over a one to eleven month period of time. Five
of the twelve sewersheds were identified as receiving elevated flows during and directly after a
precipitation event.
Under the Consent Decree, the City has agreed to investigate these five sewersheds before
January 1, 2016. The section below describes the City's progress in identifying I &I sources in
the five sewersheds (Figure 6 -1).
6.2 FLOW METERING
The City conducted flow metering within Sewershed 12 during 2011. Preliminary flow metering
results were reported in the September 30, 2011 Semiannual Report.
Flow meter locations have been established for Sewersheds 7, 5, and 10 (Appendix A).
6.3 SOURCE INVESTIGATIONS
6.3.1 Private Property Inspections
As of February 29, 2012, over 97% of all properties in Sewershed 11 and 69% of all properties in
Sewershed 12 have been inspected. Private property inspections identify the roof drain discharge
location, the presence of any stairwell or driveway drains, and the presence of a sump pit /pump
on site. A passing inspection indicates no connections of clear water to the sanitary system. A
failed inspection indicates a connection of clear water directly into the sanitary system, which
may include roof drains connected to the sanitary sewer; a stairwell or driveway drain which is
connected to the building floor drain; or a sump pump which is plumbed directly to the sanitary
lateral or a floor drain within the building.
Each improper connection observed during a private property inspection results in a failure
notice. The property owner then has 30 days to correct the improper connection, at which point a
re- inspection of the property conducted to verify that the improper connection has been
eliminated. If the improper connection has not been corrected, the City may pursue legal action
against the property owner to complete the necessary work.
Inflow & Infiltration Progra
Sanatary Sewersheds To Be Inspected
rsl
LOWELL
Mf
Figure 6-1. Map of priori
sewersheds for I &I investigation.
6.3.2 Dye Testing
Dye testing has been performed m conjunction with private property inspections If the discharge
location of a downspout, exterior stairwell drain, or dnveway dram is unknown, the City will use
dye to identify the discharge location(s) If the dye is found in the sanitary sewer, the property
owner receives notice consistent with the private property inspection process described in
Section 6 3 1
6.3.3 Smoke Testing
The City conducted smoke testing in Sewersheds 12 and 20 during September and October 2011,
respectively Although Sewershed 20 is not one of the priority sewersheds identified in the
Consent Decree, City staff felt it was necessary to identify stormwater inflow that has been
observed at a nearby wastewater pumpmg station The City expects to conduct additional smoke
testmg in 2012 in Sewershed 7 and possibly Sewersheds 5 and 10
6 -2
6.3.4 manholes
As discussed in the Sewershed 11 Corrective Action Plan, each sanitary manhole in Sewershed
11 has been opened and recorded as concrete or brick and rated based on its structural integrity
in order to prioritize its improvement or replacement. A similar process will be completed for
Sewershed 12 during 2012.
6.3.5 Sanitary Sewer
Approximately 99 °o of the public sanitary sewer within Sewershed 11 has been inspected using a
closed circuit television system. Any cracks, leaky joints, illegal lateral connections, and
damaged or broken pipes have been recorded. The severity of the structural degradation of each
pipe section will be rated based on severity. This rating system will be used to prioritize which
pipe sections are in need of immediate improvement.
6.4 CORRECTIVE ACTION PLAN
As stated in Paragraph 12 of the Consent Decree, the Sewershed 11 Corrective Action Plan was
submitted prior to December 31, 2011. A similar report will be submitted by December 31, 2012
for Sewershed 12.
6.5 InMPLEnMENTATION OF CORRECTIVE ACTION PLAN
The City is awaiting approval of the Sewershed 11 Corrective Action Plan submitted to EPA in
December 2011. Due to schedule requirements, however, work has already begun where
necessary. City staff continues to work with property owners to correct improper private
connections. The City is preparing plans and specifications to improve brick manholes and
sanitary sewer pipes.
6 -3
7.0 CMOM Update
7.1 THE CMOM PROGRAM
The City of Dubuque's Capacity, Management, Operation and Maintenance Plan (CMOM)
provides a summary of its policies, procedures, practices, and responsibilities associated with its
sanitary sewer collection system. It is the blueprint for the City's managers and field workers to
better manage, operate, and maintain Dubuque's sanitary sewer collection system, investigate
capacity- constrained area, prevent SSOs, respond to SSOs that may occur, and plan for future
system expansion.
In compliance with the Consent Decree, the City submitted the CMOM to EPA, DOJ, and DNR
on September 22, 2011.
7.2 CMOM IMPLEMENTATION
As required by Paragraph 13 of the Consent Decree, the CMOM must be fully implemented
within two calendar months after receiving formal approval by EPA. In actuality, the City
continues to implement many of the provisions of CMOM because they were already in effect at
time of CD.
The City developed the CMOM to serve as a "living" document. As the City reviews its current
procedures and codes, the CMOM will be updated and new procedures implemented as needed.
Any revisions to the CMOM will be submitted to EPA, DOJ, and DNR for review and approval
as required under the Consent Decree.
8.0 Assessments and Engineering Analyses
The City's engineering department, public works department and W &RRC staff continue to
evaluate and analyze the sewer collection system and W &RRC to ensure compliance with all
legal requirements. However, no specific study was undertaken during the reporting period.
9.0 Other Related Activities
• Submitted semiannual report on September 21, 2011. Awaiting approval by EPA.
• Submitted CMOM on September 22, 2011. Awaiting approval from EPA.
• Submitted Supplemental Engineering Project (SEP) Work Plan on September 26, 2011.
Awaiting approval by EPA.
• Submitted Sewershed 11 Corrective Action Plan on December 21, 2011. Awaiting
approval by EPA.
• At request of Department of Justice (email dated October 3, 2011), removed Mr.
Benjamin Fisherow from the list of persons to receive email notice regarding Force
Majeure events.
• Noted new address of Kate Loyd, Department of Justice is
999 18h Street, Suite 370
Denver, CO 80203 -2413
Annendix A
Proposed Sewershed 7, 5, and 10 Flow Meter Locations
Sewonhed 7 Subwatershed E)en aeon
W
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7 -3
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7 -2
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7 -1
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4
1S NOOOOOH
ALMOND ST
W LOCUST ST
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Legend
SEWKRSHFD ID
7 -1
7 -2
7 -3
7 -4
METER LOCATION
S ewers
l� l d b : 8 u Jvvat
ARROWWVOD LN
DERBY GRANGE RD _
0
r
r
z
z
i
Z fy`
BARONY DR
N
HQ NHOr M3
-
W
J
U
J
w
BITTERSWEET LN
5 -2
OR�T0� oR
pV
5 -5
DAVID
i=
m
r
SUNSET PARK RAVEN OAKS DR
1 - - - f \
( °o
MEGGAN ST ti
-4
r -1
lcd
TIFFANY CT
ARBOR HILLS DR
GI'
HUNTINGTON
SPRING VALLEY RD
m
0
5 -1
CASTLE WOODS LN
0'4KV/Ew CT
WALLER ST
MARYWOOD DR
U
w
LfSA CT
m
b
i
FOOTHILL, RD FOOTHILLI }CT
0
W KAREN ST ce
Z 0) ct
q
..V ,_2
'� U r
Z.
O
=
KATRINA CIR
KANE CT r
WESTMORE DR
L/NDALE ST
KAUFMANN AVE
c LORI ST
�SaRaH STST
i _ CORTEZ
o
-4 MA DERA ST
4
KANE ST
3 AI-TURA DR
DCERRO DR
RENAISSANCE DR
\AIRWAY DR
R
k
co
e
Z
or(
k
2
N
=1
r
Legend
SEUUERSFILD ID
5 -1
5 -2
5 -3
5 -4
5 -5
METER LOCATION
•
Sewershed
C)❑
bwa
r
r�
e
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V1P ��
OLYMPIC HTS
ROYER
KANE ST '-\ ��om
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co '���s' y�O�P
5 0 >.
P. P� , ` S�
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BERKLEY PL Q
Pa 3\14 PEE
\ SWAN DR I J
FLAMINGO DR
to
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m v«
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m o
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LANCHE AVE
RIDGEWAY AVE
o s1
o`P�,o e�5� 5�
� p tro-
\i.. � co co 44
OW
10 -3
aTH ST/
PUT$IAM
a� I
RKE r�'
-- SEWARD
MONT REST S'.
WALKER ST
'EDITH ST
O'NEILL ST
LIBERTY AVE
op
G2
i)Si- 055
5
LINK ST
rON • RIDGk'
HOGREFE ST
DAVIS ST
BURDEN ST
021 NVOY?I3HS
NAPIER ST
10 -2
5�.0
IS VIVA VN3179
CLINTON ST
i1'
3 ®HENN ST
�`L vpo E }IN
3 W 210SON1M
10 -4
5'i
S.A 0 �cn R►ES ST
r
10 -1
4 MEiI4 OR
ti
1-
a
BARRY ST
LUCREITIA ST
JANSEN
T
JUSTIN LN
10 -5
GREYHOUND PARK RD
/rg0F�
gNN4L
s
SREEH DR
i
Legend
SEWERSHED ID
10 -5
10 -4
10 -3
10 -2
10 -1
10
METER LOCATION
•