2/16/2019 1 Case Study: The City of Rome’s EPA Administrative Order Rick Kenealy, Chief Operator, City of Rome’s Municipal Sewage Treatment Plant Zarine Ali, Division of Enforcement and Compliance Assistance, USEPA Region 2 Background • EPA inspected the City of Rome’s Municipal Sewage Treatment Plant on October 26, 2017. • The inspection focused on Permit requirements for the collection system, which includes 6 NYCRR Part 750‐1 and 750‐2 • The City of Rome was issued an AO on January 24, 2018 for not having written operation and maintenance procedures for the collection system. • The AO was closed on July 3, 2018.
Transcript
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Case Study: The City of Rome’s EPA Administrative Order
Rick Kenealy, Chief Operator, City of Rome’s Municipal Sewage Treatment Plant
Zarine Ali, Division of Enforcement and Compliance Assistance, USEPA Region 2
Background• EPA inspected the City of Rome’s Municipal Sewage Treatment Plant on October 26, 2017.
• The inspection focused on Permit requirements for the collection system, which includes 6 NYCRR Part 750‐1 and 750‐2
• The City of Rome was issued an AO on January 24, 2018 for not having written operation and maintenance procedures for the collection system.
• The AO was closed on July 3, 2018.
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750‐2.8 Disposal system operation and quality control includes part (a)(2)
The permittee shall, at all times, properly operate and maintain all disposal facilities, which are installed or used by the permittee to achieve compliance with the conditions of the permit.
(i) a preventive/corrective maintenance program for all critical facilities and systems of treatment and control (or related appurtenances)
(ii) written procedures for operation and maintenance
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750‐2.9 Additional conditions applicable to a publicly owned treatment works (POTW) includes (a) parts (3) and (4)
(a) General
(3) The permittee shall identify all inflow to the tributary system and remove excessive infiltration/inflow to an extent that is economically feasible
(4) The permittee shall enact, maintain and enforce or cause to be enacted, maintained and enforced up‐to‐date and effective Sewer Use Law in all parts of the POTW service area. Such enactment and enforcement shall include intermunicipal agreements and/or other enforceable legal instruments
750‐2.8 Disposal system operation and quality control
(g) POSS Operation Requirements
Owners and operators of POSSs must properly operate and maintain the POSS. Proper operation and maintenance includes at a minimum, the following:
(1) a preventive/corrective maintenance program for all critical components of the collection system that includes provisions requiring the maintenance of installed backup or auxiliary components or similar systems when the proper operation of such component or system is essential for preventing discharges of untreated or partially treated sewage; and
(2) Written procedures for operation and maintenance of the POSS and training new operators.
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The Collection System
• What are the upstream contributors and downstream destination and provide a copy of any applicable intermunicipal agreement governing the conveyance of wastewater
• Is the collection system separate
• Age of the system components/construction materials
• Pipe sizes and lengths throughout the system
• Is the collection system mapped
• Number of manholes
• What is the host WWTP
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Pump Stations
• Capacity of each station
• Alarm status and emergency power generation at each station
• Provide annual, monthly, daily and peak flows for the past 2 years (or equivalent information which demonstrates that the pumping stations are being operated without the occurrence of SSO discharges).
Flow Metering and Billing
• Describe how flows are metered and provide flow data for the last year.
Are there flow meters within the collection system.
Has there been flow studies
• Describe how wastewater cost are billed and provide representative billing record(s)
Are residents billed based on water usage, taxes, flat rate, quarterly etc.
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SSO Discharges/ Spills
(SSOs or Spill: any releases, spills, or discharge of wastewater from or caused by a sewage collection system, and not private lateral, to public or private property (including basement backups) whether or not it reached a surface water)
• Does the municipality have written procedures for responding to and reporting sanitary sewer overflows or spills?
If yes, provide a copy of these procedures.
Has the municipality experienced any sanitary sewer overflows (SSOs) or spills in the past 5 years?
If yes, please provide a complete inventory of SSOs and spills for the past 5 years. Please ensure that the following information is included:
Type of overflow/spill (i.e., SSO, basement backup, etc.)
Date of overflow or spill
Location and Volume
Main cause and
Receiving waterbody
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Residential Complaints• Has the municipality received any citizen complaints regarding the release of sewage into private residences or onto private property during the past 5 years.
• If yes, please provide a complete inventory of events by year and the cause of the overflows for the past 5 years.
• In no, please provide a summary of how citizen complaints would be managed if received.
Collection System Insurance
• Is insurance maintained maintained for the collection system?
• If so, provide as list of all insurance claims paid, as a result of SSOs or spills, to affected property owners for the past 5 years.
• If not, provide information on how residents are compensated for damages resulting from SSOs or spills?
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Capacity Issues
• During the past 5 years, has the municipality experienced any capacity issues, force main failures, collection system cave‐ins, pump station spills, or issues related to oil and grease?
• If yes, please provide a complete inventory of events by year including a description of the events that clearly denotes the cause of the event and the receiving water, if any.
Collection System Maintenance
• Discuss and describe how excessive infiltration is minimized
• Discuss and describe how inflow is eliminated
• Local law prohibiting inflow
• Describe preventive maintenance (e.g., schedules, cleaning, root cutting, etc.) program and provide documentation
• Describe corrective maintenance program and provide documentation
• Sewer breaks, Sewer backups and know trouble spots
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Cleaning• What percentage of the sewer is cleaned annually?
• At what frequency is the entire system cleaned (e.g., once every 3 years) ?
• Is closed‐circuit television (CCTV) equipment used to inspect the sanitary sewer system?
If yes, what percentage of the system is inspected on an annual basis?
• Does the City have a Fats, Oils, and Grease (FOG) Program?
If yes, please provide a summary of the program.
Municipal Separate Storm Sewer System (MS4)
• Does your municipality currently have a Stormwater Management Program for detecting and eliminating illicit discharges (Illicit Discharge Detection and Elimination program (IDDE program)?
• If so, what is the date of your final IDDE plan, and what are the procedures for identifying, locating, and documenting cross connections between the sanitary and storm water collection systems.
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• Does the municipality have an ordinance to prohibit illicit discharges and dumping to the MS4? If so, what exclusions are included in this ordinance?
• What enforcement mechanisms are authorized in the event of an illicit discharge being detected?
• Has an enforcement escalation plan to address illicit discharges been developed and implemented?
Lessons Learned in the Field• Make sure everyone at the WWTP is aware that the EPA does
inspections. Some inspections are unannounced.
• Don’t do anything stupid/dangerous during an inspection to impress the EPA.
• If additional documents/info is needed after an inspection, please reach out to EPA if additional time is needed for a response.
• Make sure you have the most recent SPDES Permit. The effluent limits might be the same, but new regulations might be incorporated into a new Permit.
• If you use the word bypass during an inspection, explain what you mean.
• Recurrent overflow locations which are not listed in a Permit, these are not permitted.
• Prepare for an inspection.
• Don’t contradict your fellow co‐workers during an inspection. If you are not sure of a fact, simply say that you will follow up with the inspector.
• If you are issued an AO to develop an O&M manual for the collection system, please work on it.
• Documentation of maintenance/work done is not written O&M procedures for the collection.
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City of Rome, NYWater Pollution Control FacilityDesign Flow: 12 MGDDischarge: Mohawk River
Original Plant: 1937 (Primary Treatment)1st Major Upgrade: 1976 (Secondary Treatment)
Collection System:• 27 Pump Stations
• 7 Main Stations• 20 Lift Stations
• Miles of Sanitary Sewer• 175 miles sanitary sewer lines
EPA Inspection
Prior to actual inspection:
Notification of upcoming Inspection
Phone conversations and emailsEase of information exchange
Extremely helpful and cooperative
Questionnaire
Data gathering
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EPA Inspection
Day of inspection:
Meeting to go through data collection and questionnaire
Facility walk‐through
Visiting of Pump Stations
Closing Meeting
Administrative Compliance
Order
Received on January 24,
2018
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#1 – Sign Acknowledgement Page
#2 – Submit to NYSDEC and EPA a written O & M Manual for our collection system by May 1, 2018.
Now what??
What next?First off……
From this in‐depth inspection, we didn’t have an O & M Manual for our collection system.
We had procedures in place, just not memorialized.
What next ‐ Decision making
Produce the manual in house?
Hire outside assistance?
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Develop O & M Manual In‐HouseEPA guidance invaluable
Examples of various O & M manualsEngineering Company developed
In‐house developed
Weighed out various costsEvaluated Engineering Costs
Estimated In‐house costsMostly time & labor
Administration’s approval for In‐house development of O & M manual
Process of O & M DevelopmentIn‐house cooperation Operations – Assist in developing manual
Maintenance – Memorialize institutional knowledge
Procedure – Verify current procedures
Interdepartmental cooperation Water Pollution Control
Engineering – Street Program
Water Department – Maintaining collection system
Codes Department – Enforcing Sewer Use Ordinance
Estimate time for development and completion –May 1, 2018
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Process of O & M Development• Read & study sample O & M Manuals
• “EPA’s Template for Developing Sewer Collection System Preventative Maintenance and Sewer Overflow Response Plans”
• Document current procedures & programs• Disseminate requested information to pertinent departments• Gather & sort departmental information
During this whole process, we were in constant contact with EPA making sure we were covering all of the important aspects of an acceptable O & M manual.
• Extension?
Extension RequestEmailed EPA asking for extension – April 9, 2018
Requesting 2 month extension from May 1, 2018 to July 1, 2018.
Approved for extensionReceived requested extension approval letter via email –April 9, 2018
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O & M Manual Completion and Submission
Manual CompletionCompleted manual on June 27, 2018
Emailed completed manual to the EPA on June 28, 2018
EPA Close‐out Letter – July 3, 2018“EPA’s assessment is that the requirements mandated in the above referenced Administrative Order have been satisfactorily met, thereby closing out this EPA enforcement action”.
1. Regulatory enforcement actions are not always a negative thing;
2. EPA was more of a teammate than an adversary;
3. Your facility may be doing everything necessary to operate and maintain for facilities correctly, but have not documented your procedures;
4. The importance to tap into long time employees knowledge and experience and transfer that to pen & paper cannot be stressed enough.
5. Using your own resources and inter‐departmental cooperation, you may be able to accomplish tasks that sometimes get hired out.
