Consent Decree Semi Annual Report_March 2013Masterpiece on the Mississippi
TO: The Honorable Mayor and City Council Members
FROM: Michael C. Van Milligen, City Manager
SUBJECT: Consent Decree Semi - Annual Report
DATE: February 26, 2013
Dubuque
kital
All- America City
II 111!
2012
City Engineer Gus Psihoyos recommends City Council approval for the City Manager to
certify the March 31st Semi Annual Consent Decree Report to be submitted to the U.S.
Department of Justice, U.S. EPA and the Iowa Department of Natural Resources.
I concur with the recommendation and respectfully request Mayor and City Council
approval.
duat4A., krt., italy,
Michael C. Van Milligen
MCVM:jh
Attachment
cc: Barry Lindahl, City Attorney
Cindy Steinhauser, Assistant City Manager
Teri Goodmann, Assistant City Manager
Gus Psihoyos, City Engineer
Masterpiece on the Mississippi
TO: Michael C. Van Milligen, City Manager
FROM: Gus Psihoyos, City Engineer
Dubuque
kittel
1104unericaCity
If
2012
SUBJECT: March 31 Semi Annual Report
US EPA Consent Decree Required Submittal
DATE: February 25, 2013
INTRODUCTION
The purpose of this memorandum is to request City Council approval to authorize the
City Manager to certify and submit to the appropriate parties, the City of Dubuque's
March 31st Semi Annual Report, a Consent Decree required submittal.
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. Per the Consent Decree, the City is required to
submit a Semi Annual Report each March 31st and September 30th after the effective
date of the Consent Decree.
DISCUSSION
The purpose of the Semi Annual report is to present events and activities associated
with the WRRC and the Sanitary Sewer Collection System since approval of the
Corrective Action Plans. The report specifically includes documentation on all Sanitary
Sewer Overflows, a summary and status of projects including the WRRC Upgrades, a
listing of all NPDES violations, and efforts and actions taken to reduce sources of
infiltration and inflow.
ACTION TO BE TAKEN
I respectfully request the City Council approve and authorize the City Manager to certify
the March 31st Semi Annual Report and Engineering staff to submit the certified report
to the US Department of Justice, US EPA and the Iowa Department of Natural
Resources.
cc: Barry Lindahl, City Attorney
Denise Ihrig, 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, 2013
Consent Decree No. 2:11 -cv- 01011 -EJM
February 25, 2013
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 -3
3.1 Sanitary Sewer Overflow Record 3 -3
3.2 SSO's Effect on Public Health and Water Quality 3 -4
3.3 Measures Enacted to Minimize Duration and Impact 3 -4
3.4 Measures Enacted to Stop the Overflow Event 3 -4
3.5 Measures Enacted to Prevent Another Recurrance 3 -4
3.6 Capturing Key Way Overflows 3 -4
3.7 Warning Sign Postings 3 -4
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 -3
6.3.3 Smoke Testing 6 -3
6.3.4 Manholes 6 -3
6.3.5 Sanitary Sewer 6 -3
6.4 Corrective Action Plan 6 -3
i
6.5 Implementation of Corrective Action Plan 6 -3
7.0 CMOM UPDATE 7 -1
7.1 The CMOM Program 7 -1
7.2 CMOM Implementation 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 -3
Table 3 -2. Warning sign posting locations. 3 -4
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
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, 2012 and February 28, 2013.
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. Orsanizatiion 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 iii
ro)
NPDES permit violations during reporting
period
5 2
8
Assessments and engineering analyses
8.0
9
Disposal of biosolids 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(c)
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
Five (5) dry weather sanitary sewer overflows occurred during the reporting period. Table 3 -1
lists the locations and details the overflows. The times reported as Start Times document when
the call came into the Public Works department, it is difficult to know the precise time of the
start of the overflow as it is reliant upon when a member of the public sees the occurrence.
Table 3 -1. Sanitary sewer overflows during the reporting period.
FY 2013 July 1 through June 30
No. Date Reported
2/6/2013
11/16/2012
10/15/2012
11/14/2012
Location
Carter Road Detention Basin
2112 St Ambrose
Fairfield Inn
245 Julien Dubuque Dr
419 Lowell
2155 N Main at Kaufmann
Cottage Place
Sewershed
5
7
7
7
GIS Ref
SAN P 04758
SAN P 07142
SAN P 02100
SAN P 03582
SSO #
1
2
3
4
5
6
Sewershed
6
2
14
8
5
20
Street Address
1110 W. 32 °d
Street*
55 John F
Kennedy
Road
Cross Street
and Coates
Street
925 Kerper
Court
Carter Road
Detention
Basin
600 Star
Brewery
Drive*
Start Date
9/26/2012
10/8/2012
12/22/2012
1/22/2013
2/4/2013
2/4/2013
End Date
9/26/2012
10/8/2012
12/22/2012
1/22/2013
2/4/2013
2/4/2013
Start Time
6:00 PM
Unknown
11:00 AM
3:00 PM
8:30 AM
5:15 PM
End Time
6:45 PM
3:00 PM
11:45am
4:00 PM
1:30 PM
6:00PM
Overflow
Volume, Gal
5
100
100
30
500 -700
10
Downstream
Wate rbody
Bee Branch
Creek
Catfish
Creek
Catfish Creek
Ivlississippi
River
Bee Branch
Creek
Mississippi
River
Suspected Cause
Roots
Grease
Pipe Failure
Grease
Roots
Grease
3 -3
Description of U1
Pipe replacemer
Point repair at 4
Point repair at 7
Point repair at 3
* Basement backup
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. For each
incident in the public right of way, the Public Works department cleans the area and posts the
required SSO signs.
3.3 MEASURES ENACTED TO MINIMIZE DURATION AND IMPACT
The City minimized the duration and impact of the SSOs by quickly responding to the event after
it was called in and setting up a City owned vacuum jet truck to jet the sewer main and remove
the blockage.
3.4 MEASURES ENACTED TO STOP THE OVERFLOW EVENT
The overflow event was controlled and stopped by removing the blockage using the vacuum -jet
equipment. Regarding SSO No. 6 at the Carter Road Detention Basin, a spill containment area
was established and a 3 -inch pump collected untreated wastewater and pumped it back into the
sanitary sewer system downstream of the overflow.
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 work on proactive
methods to implement the Fats, Oils, and Grease (FOG) ordinance and reduce 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. No sanitary
sewer overflows occurred at this location during the reporting period.
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
55 John F Kennedy Road
Adjacent to Walgreens at the Intersection of Dodge
and JFK
Cross Street and Coates Street
SW Corner of the Intersection and at the End of the
Storm Sewer Pipe
3 -4
Carter Road Detention Bas in
Posted in the Detention Bas in at the location of the
SSO and behind 3101 and 3105 Arbor Oaks Drive
3 -5
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 and 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 the revised significant deadlines for
the project, which take into account project delays resulting from force majeure.
Table 4 -1. Significant deadlines for the Water & Resource Recovery Center.
Deadline
Target Date
Digester Startup
January 7, 2013
Sludge Processing Startup
February 6, 2013
Excess Flow Equalization
April 18, 2013
Aeration Tank Completion
June 21, 2013
Final Clarifiers
August 8, 2013
Substantial Completion
September 3, 2013
Final Completion
February 3, 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 causing 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.
4 -1
The City estimates a project delay of approximately three to four months beyond the original
final completion date of October 1, 2013, pushing project completion to January /February of
2014; Table 4 -1 reflects this change. The City has since granted a 120 working day extension to
the two major milestones: digester startup and sludge processing startup. The City and its general
contractor continue to work on details to meet the project completion schedule required by the
Consent Decree. Factoring in the delays, the City will strive to meet the startup deadline (April
26, 2014) as prescribed in the Consent Decree barring any further unforeseen delays.
Through February 28, 2013, the project is in its 30th month of construction and work has started
on all aspects of the project. Through this reporting period, City staff estimates the project is
close to 87% complete with an expenditure of approximately $47,730,901.00. The ultraviolet
disinfection system was started in March 2011 and continues to be operational. The Anaerobic
Digestion complex started up August 9, 2012. On August 20, 2012 seed sludge was added to the
digesters, with solids from the Dubuque plant added to the digesters shortly thereafter. With a
successful startup of the digesters in January 2013, the City installed the new solids handling
equipment which came on -line in February 2013. A bio -solid handling contract was negotiated
and signed with Nutri -Ject Systems of Hudson, Iowa.
The laboratory addition of the Administration/Laboratory Building (A &L Building) is complete
and work is close to completion on the rebuilding of the existing Administration/Laboratory
building. The A &L Building will be a high energy efficient building using plant effluent to meet
heating and cooling needs. With extensive insulation, the building will use very little energy for
lighting, heating and cooling.
4.3 BIOSOLID ACCUMULATION PREVENTION AT THE W &RRC
On April 5, 2012 there was an explosion at the W &RRC which destroyed the main blower for
the North incinerator and severely damaged the recuperator. As the digesters would have been
online sooner than the incinerator would be repaired, it prompted a decision to not repair the
incinerator, but instead begin hauling solids to the Dubuque Area Metropolitan Sanitary Landfill.
Alternative arrangements were also made with Waste Management Inc. to haul solids to its
landfill facility in East Moline, Illinois.
In February 2013, the City installed the new solids handling equipment (two centrifuges), and
entered into a contract with Nutri -Jet Systems of Hudson, Iowa to manage the bio- solids, thereby
preventing accumulation of bio - solids at the W &RRC.
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 oneratine reports submitted durin the reporting period.
Report
Date Submitted
August 2012
9/7/2012
September 2012
10/12/12
October 2012
11/15/12
November 2012
12/13/12
December 2012
1/15/13
January 2013
2/15/13
February 2013
before 3/15/13
5.2 NPDES VIOLATIONS AT THE WRRC DURING THE REPORTING PERIOD
There were violations of the monthly and seven -day averages for BOD and TS S for the month of
December 2012 and a monthly average violation for BOD for January 2013.
5.2.1 NPDES Violation(s) Log
December 2012 BOD TSS
Monthly average 31 mg/L 44 mg/L
Permit limit 25 mg/L 30 mg/L
Seven Day Average
12/15/12- 12/21/12 44 mg/L 52 mg/L
Permit Limit 40 mg/L 45 mg/L
January 2013
Monthly Average
Permit Limit
29 mg/L
25 mg/L
5.2.2 Cause of NPDES Violations
At various times in December 2012 and January 2013, during the construction process it was
necessary for the W &RRC to operate using only two of the four final clarifiers; only three final
clarifiers have been online for the duration of the project. In order to replace effluent gates at the
clarifiers it was essential to go to only two clarifiers for periods of time. As of February 22, 2013
all effluent gates were replaced. Moving forward, three clarifiers should be available.
5 -1
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 sewersheds 12, 11, and 7 during 2012 and will
continue to do so in 2013. There were no significant rain events during the reporting period;
however the flow meters did record good baseline data for subbasins within each of the sewer
sheds listed. Flow meters for sewershed 7 are being reset for the Spring rain period and the
baseline flow data from the Winter will be used to assist the City with determining key I &I
locations.
Based upon a recent evaluation of the sewersheds, the flow meter locations will be changed to
reflect sub -basin flow to verify improvements performed are having the desired effect. Flow
meter locations have been established for sewersheds 5 and 10, but are subject to change as new
televising information is reported showing more ideal locations for installing the transducers and
sleeves providing a better picture on how flow is moving through the sewersheds. In addition,
the City is looking at placing permanent flow monitoring sites throughout the key areas, possibly
starting with a location in sewershed 11.
6.3 SOURCE INVESTIGATIONS
6.3.1 Private Property Inspections
Private property inspection progress is reported in Table 6 -1. 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
6 -1
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.
Table 6 -1. Property inspection nro ress.
Sewershed
Percent of Completed Property
Inspections*
Consent Decree Deadline to Complete
Property Inspections
11
100
9/30/11
12
96.5
6/30/12
7
90.2
6/30/ 13
5
14.8
6/30/14
10
None
6/30/15
*The Consent Decree does not state that all properties must be inspected. However, it is the City of Dubuque's
intent to inspect 100% of the properties in each sewershed.
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
OIESELO
Inflow & Infiltration Progra
Sanitary Sewers heds To Be Inspected
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Dubuque City limits.
DAGIS;
Figure 6 -1. Map of priority sewersheds for I &I investigation.
6 -2
6.3.2 Dye Testing
Dye testing has been performed in conjunction with private property inspections. If the discharge
location of a downspout, exterior stairwell drain, or driveway drain 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 Sewershed 12 to confirm the location of where
improvements will be necessary. In addition, the City is working closely with owners of large,
older properties such as schools, to identify possible sources of I &I, and while many of the
facilities may be outside the original five sewersheds, all sewer sheds lead to the treatment plant
potentially adding to overflows and surcharges. Entities such as the schools have welcomed the
opportunity to work with the City in helping to resolve any I &I contribution that may be coming
from their facilities. The City expects to conduct additional smoke testing in 2013 in Sewershed
7 and 5 and possibly Sewershed 10.
6.3.4 Manholes
As discussed in the Sewershed 12 Corrective Action Plan, each sanitary manhole in Sewershed
12 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 7 during 2013.
6.3.5 Sanitary Sewer
Approximately 95% of the public sanitary sewer within Sewershed 12 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 12 Corrective Action Plan was
submitted prior to December 31, 2012. A similar report will be submitted by December 31, 2013
for Sewershed 7.
6.5 IMPLEMENTATION OF CORRECTIVE ACTION PLAN
The City is awaiting approval of the Sewershed 12 Corrective Action Plan submitted to EPA in
December 2012. Due to schedule requirements, however, work will be scheduled where
necessary and as budget allows. 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 S SOs, respond to SSOs that may occur, and plan for future
system expansion.
The City received notice from the EPA that the CMOM had been approved on June 4, 2012.
7.2 CMOM IMPLEMENTATION
As required by Paragraph 13 of the Consent Decree, the City fully implemented the CMOM
within two calendar months (August 4, 2012) of approval by the EPA.
Section 6.4 of the City of Dubuque's CMOM Program, requires the City to annually inspect fifty
miles of gravity sanitary sewer through various methods including visual inspection, pipeline
jetting, or closed- circuit televising (CCTV). The inspection is in addition to the predictive and
preventive maintenance also prescribed in the CMOM. During the last two reporting periods
covering the year 2012, the City cleaned and inspected 25.43 miles of gravity sanitary sewer and
performed inspections on an additional 155.25 miles, exceeding the requirements of the CMOM
program.
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.
The City is currently focused on the Fats, Oils, and Grease Program covered by the CMOM, as
several of the dry weather sanitary sewer overflows are the result of grease in the public sewer
from private establishments.
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
• The City submitted Sewershed 12 Corrective Action Plan on December 11, 2012.
Awaiting approval by EPA.
• The City of Dubuque hired a new Environmental Engineer to oversee compliance and
reporting requirements of the Consent Decree, the previous engineer, Todd Shoemaker
has moved on from the City. The new engineer is Denise Ihrig and she can be reached
directly at 563.690.6034, cell phone 563.599.2207, or email dihrig @cityofdubuque.org.