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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 `44rH /LS KENNEDY RD O DERBY GRANGE RD BOLEYNR Dus E LEERFY AV£ S ✓0 S �j." Sewershed 10 ��F, s r RLB,,O ti OLYMPIC HTS DAMS ST OLEEL ST w 32ND ST cb1D DR UKt_ �T ERKLE, PL LRO KAUFMANN AVE • Z o D o ❑ m < ER OP m OLFF RD o PENN Op ECHOER : LE RD N O A P � 61/15 as rR SI LOWELL ST HILLCREST RD ' z z SAO ANNE OR K YLVANIA AVE o SNRNFY OR S t'NI£W DODGE ST i 0 BRUNSKILL RD 1 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.