HomeMy WebLinkAbout10/19/2019 Council Work Session
October 19, 2015
Time indicated below
Harold E. Getty Council Chambers
Roll Call.
Approval of Agenda, as proposed or amended.
4:20 p.m. Consent Decree
ADJOURNMENT
Suzy Schares, CMC
City Clerk/Human Resource Director
IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF IOWA
EASTERN DIVISION
THE UNITED STATES OF AMERICA
and
THE STATE OF IOWA,
Civil Action No.
Plaintiffs,
V. CONSENT DECREE
THE CITY OF WATERLOO, IOWA
Defendant.
TABLE OF CONTENTS
I. JURISDICTION AND VENUE 5
II. APPLICABILITY 5
III. OBJECTIVES 7
IV. DEFINITIONS 7
V. REMEDIAL MEASURES AND SCHEDULES 11
A. Short-term Remedial Measures 12
B. Capacity, Management, Operations, and Maintenance (CMOM) Program Plan 13
C. Sanitary Sewer Overflow Response Plan (SSORP) 13
D. Rainfall and Flow Monitoring 13
E. Sewer System Condition Assessment 14
F. Hydraulic Model 14
G. Capacity Assessment 15
H. Sanitary Sewer Master Plan 15
VI. DEMONSTRATION AND ELIMINATION OF OVERFLOWS 18
VII. REVIEW AND APPROVAL PROCEDURES 19
VIII. CIVIL PENALTY 21
IX. REPORTING REQUIREMENTS 23
X. STIPULATED PENALTIES 25
XI. FORCE MAJEURE 30
XII. DISPUTE RESOLUTION 32
XIII. INFORMATION COLLECTION AND RETENTION 34
XIV. EFFECT OF SETTLEMENT/RESERVATION OF RIGHTS 37
XV. COSTS 39
XVI. NOTICES 39
XVII. CERTIFICATION 41
XVIII. EFFECTIVE DATE 41
XIX. RETENTION OF JURISDICTION 41
XX. MODIFICATION 42
XXI. TERMINATION 42
XXII. PUBLIC PARTICIPATION 43
XXIII. SIGNATORIES/SERVICE 44
U.S. & State of Iowa v. City of Waterloo—Consent Decree- Page 2 of 51
XXIV. INTEGRATION 44
XXV. FINAL JUDGMENT 44
XXVI. APPENDICES 45
WHEREAS, Plaintiff United States of America, by authority of the Attorney General of
the United States and through the undersigned attorneys, acting at the request and on behalf of
the Administrator of the United States Environmental Protection Agency(EPA), and Plaintiff
State of Iowa (State), by authority of the Attorney General of Iowa and through the undersigned
attorneys, have filed a Complaint concurrently with this Consent Decree, seeking injunctive
relief and civil penalties against Defendant City of Waterloo (City), pursuant to Sections 309(b)
and (d) of the federal Clean Water Act (CWA), 33 U.S.C. § 1319(b) and(d), and Iowa Code
§ 455B.191.
WHEREAS, the State is a party to this action pursuant to Section 309(e) of the CWA, 33
U.S.C. § 1319(e), and has joined this action as a co-plaintiff.
WHEREAS,the City owns and operates a wastewater treatment facility and sanitary
sewer system, which is a"publicly owned treatment works"within the meaning of 40 C.F.R.
§ 403.3 and a"disposal system"within the meaning of Iowa Code § 455B.171(5), and which
receives and treats domestic sewage and wastewater in the Waterloo area.
WHEREAS,the City holds a National Pollutant Discharge Elimination System
(NPDES) Permit issued by the Iowa Department of Natural Resources (IDNR), as authorized by
EPA under Section 402(b)of the CWA, 33 U.S.C. § 1342(b), and Iowa Code § 455B.174(4)(a).
The NPDES Permit contains defenses to certain penalties in provisions relating to bypass
(Standard Condition 23) and upset (Standard Condition 24).
WHEREAS, the Complaint alleges that the City has violated, and could continue to
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violate, Section 301(a) of the CWA, 33 U.S.C. § 1311(a),Iowa Code § 455B.186(1) and 567
IAC 62.1(1) and 64.3(1), and the City's NPDES Permit,by: (1) discharging untreated sewage
from its publicly owned treatment works, including but not limited to Sanitary Sewer Overflows
(SSOs) and Prohibited Bypasses, as defined in Section IV of this Consent Decree; (2)
discharging pollutants from its wastewater treatment facility in excess of the City's NPDES
Permit, and (3) failing to comply with conditions in the NPDES Permit pertaining to operations
and maintenance and Prohibited Bypasses. The City contends that the City's NPDES Permit
provides defenses applicable to those claims.
WHEREAS,the Cedar River valley was subject to two major flooding events during the
years 2008 and 2010 that rendered portions of the City's collection system inoperable and caused
widespread sewer overflows. The City contends that these conditions and their residual effects
were beyond the City's control.
WHEREAS, the City has developed both a Sanitary Sewer Overflow Response Plan
(SSORP), and a Capacity, Management, Operations, and Maintenance (CMOM) Program Plan,
and both the SSORP and the CMOM Program Plan have been reviewed and accepted by EPA
and IDNR.
WHEREAS, some areas of the City's Sanitary Sewer System receive significant flows
from basement footing drains that were designed to route groundwater to the sanitary sewers,
and the City has taken action to address these flows by developing a Footing Drain Removal
ordinance, implementing a Footing Drain Removal Program in portions of the City, and
establishing flow monitoring mechanisms in those portions of the City that will allow the City to
determine the contribution of footing drains to flow within the City's Sanitary Sewer System.
WHEREAS,the City does not admit any liability to the United States or the State arising
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out of the transactions or occurrences alleged in the Complaint.
WHEREAS,the Parties agree that the United States' filing of the Complaint and entry
into this Consent Decree constitute diligent prosecution by the United States under Section 505
of the CWA, 33 U.S.C. § 1365, of all matters alleged in the Complaint and addressed by this
Consent Decree through the Date of Lodging of the Decree.
WHEREAS,the Parties recognize, and the Court by entering this Consent Decree finds,
that this Consent Decree has been negotiated by the Parties in good faith and will avoid litigation
between the Parties, and that this Consent Decree is fair, reasonable, and in the public interest.
NOW THEREFORE, with the consent of the Parties, IT IS HEREBY ADJUDGED,
ORDERED,AND DECREED as follows:
I. JURISDICTION AND VENUE
l. This Court has jurisdiction over the subject matter of this action, pursuant to
28 U.S.C. §§ 1331, 1345, and 1355, and Section 309(b) of the CWA, 33 U.S.C. § 1319(b), and
over the Parties. This Court has supplemental jurisdiction over the state law claims asserted in
the Complaint pursuant to 28 U.S.C. § 1367(a), because the state claims are so related to the
federal claims as to form part of the same case or controversy. Venue lies in this District
pursuant to 33 U.S.C. § 1319(b) and 28 U.S.C. §§ 1391(b) and 1395(a), because it is the judicial
district where the City is located and where the alleged violations occurred. For purposes of this
Decree, or any action to enforce this Decree,the City consents to the Court's jurisdiction over
this Decree and any such action and over the City and consents to venue in this judicial district.
II. APPLICABILITY
2. The obligations of this Consent Decree apply to and are binding upon the City and
its officers, directors, employees, agents, servants, successors, assigns, and all persons, firms and
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corporations under contract with the City to perform obligations of this Consent Decree, and
upon the United States and the State, and their agencies, departments, representatives,
employees, successors and assigns, and upon other entities or persons otherwise bound by law.
3. No transfer of ownership or operation of any portion of the City's publicly owned
treatment works, whether in compliance with the procedures of this Paragraph or otherwise, shall
relieve the City of its obligation to ensure that the terms of the Decree are implemented. At least
thirty(30) Days prior to such transfer,the City shall provide a copy of this Consent Decree to the
proposed transferee and shall simultaneously provide written notice of the prospective transfer,
together with a copy of the proposed written agreement, to the EPA,the United States
Department of Justice, and the State, in accordance with Section XVI (Notices). Any attempt to
transfer ownership or operation without complying with this Paragraph constitutes a violation of
this Decree.
4. The City shall provide a copy of this Consent Decree to all officers, directors,
employees, and agents whose duties might reasonably include compliance with any provision of
this Decree, as well as to any contractor retained to perform work required under this Consent
Decree. The City shall condition any such contract upon performance of the work in conformity
with the terms of this Consent Decree.
5. EPA and IDNR will provide a copy of this Consent Decree to their permitting
program staff to allow for communication of Consent Decree requirements to all relevant
departments.
6. Any action taken by any contractor or consultant retained to implement the City's
obligations under this Consent Decree shall be considered an action of the City solely for
purposes of determining compliance with this Consent Decree. In any action to enforce this
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Consent Decree, the City shall not assert as a defense the failure by any of its officers, directors,
employees, agents, contractors, consultants, successors or assigns to take any actions necessary
to comply with the provisions of this Consent Decree.
III. OBJECTIVES
7. The express purpose of the Parties entering into this Consent Decree is for the
City to take all necessary measures to achieve full compliance with the CWA,the Iowa water
pollution control laws, and all applicable federal and state regulations, as implemented through
the City's NPDES Permit,with the goal of eliminating SSOs,Building Backups, and Prohibited
Bypasses. All plans, reports, construction, remedial maintenance, and other obligations in this
Consent Decree, and under any amendment to this Consent Decree, shall have the objective of
ensuring that the City complies with the CWA, the Iowa water pollution control laws, and all
applicable federal and state regulations, as implemented by the terms and conditions of its
NPDES Permit.
IV. DEFINITIONS
8. Terms used in this Consent Decree that are defined in the CWA or in regulations
promulgated under the CWA shall have the meanings assigned to them in the CWA or such
regulations, unless otherwise provided in this Decree. Whenever the terms set forth below are
used in this Consent Decree,the following definitions shall apply:
a. "Adequate Capacity" shall mean the ability to collect, convey and treat peak wet
weather flows as determined through the Capacity Assessment(Section V.G) and
Master Plan(Section V.H).
b. "Building Backup" shall mean a wastewater backup occurring into a building that
is caused by blockages, flow conditions, or malfunctions in the Sanitary Sewer
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System or WWTPs. Building Backups do not include wastewater backups that
are caused by blockages or other malfunctions within a private lateral that is not
owned or operationally controlled by the City.
c. "Calendar Year" shall mean the twelve(12) month period starting on January 1
and ending on December 31.
d. "Capacity, Management, Operations, and Maintenance Program Plan"or
"CMOM Program Plan" shall mean, for the purpose of this Consent Decree, a
flexible program of accepted industry practices to properly manage, operate and
maintain the City's Sewer System and WWTPs; respond to SSOs, Building
Backups, and Prohibited Bypasses; and, in conjunction with implementation of
the Master Plan described in Section V.H, investigate and maintain and/or
improve the capacity of the Sewer System and WWTPs.
e. "Certification" or"certify" when used in this Consent Decree shall require the
City to comply with Section XVII of this Consent Decree.
f. "City" shall mean the Defendant City of Waterloo, Iowa.
g. "Complaint" shall mean the complaint filed by the United States and the State in
this action.
h. "Consent Decree"or"Decree" shall mean this Decree and all appendices attached
hereto. In the event of a conflict between this document and any appendices,this
document shall control.
i. "Date of Lodging" shall mean the date on which this Decree is lodged with the
United States District Court for the Northern District of Iowa for a period of
public comment.
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j. "Day" or"Days" (whether or not capitalized) shall mean a calendar day or
calendar days unless expressly stated to be a business day. In computing any
period of time under this Consent Decree, where the last day would fall on a
Saturday, Sunday, or federal or state holiday, the period shall run until the close
of business of the next business day.
k. "Deliverable"shall mean any written document or other work product, whether in
hard copy or electronic format, required to be prepared and/or submitted by or on
behalf of the City pursuant to this Decree.
1. "EPA" shall mean the United States Environmental Protection Agency and any of
its successor departments or agencies.
m. "Effective Date" shall have the definition provided in Section XVIII of this
Consent Decree.
n. "Force Main" shall mean any Sewer System line that operates under pressure due
to pumping of wastewater at a Pumping Station, except for those Sewer System
lines that serve a single structure or building.
o. "Gravity Sewer Line" shall mean a Sewer System line that receives, contains and
conveys wastewater not normally under pressure, but is intended to flow
unassisted under the influence of gravity.
p. "I/I" shall mean the total quantity of water from Infiltration and Inflow without
distinguishing the source.
q. "Infiltration" shall mean water other than wastewater that enters the Sewer
System as defined by 40 C.F.R. § 35.2005(b)(20).
r. "Inflow" shall mean water other than wastewater that enters the Sewer System as
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defined by 40 C.F.R. § 35.2005(b)(21).
s. "NPDES Permit" shall mean National Pollutant Discharge Elimination System
permit number IA0042650 issued to the City by IDNR pursuant to Section 402 of
the CWA, 33 U.S.C. § 1342, as in effect on the Date of Lodging of this Decree,
and any future extended, modified or reissued permit.
t. "Paragraph" shall mean a portion of this Decree identified by an Arabic numeral.
u. "Parties" shall mean the United States, the State, and the City.
v. "Plaintiffs" shall mean the United States and the State.
w. "Prohibited Bypass" shall mean a bypass within the meaning of 567 IAC 60.2, but
does not include split-flow operations otherwise approved within the City's
NPDES Permit.
x. "Pumping Station" (also referred to as a lift station or pump station) shall mean a
facility, owned or operated by the City, comprised of one or more pumps that lift
wastewater to a higher hydraulic elevation or increase the flow rate/volume
through the Sewer System, including all related electrical, mechanical, and
structural systems necessary to the operation of that pumping station.
y. "Sanitary Sewer Overflow"or"SSO" shall mean an overflow, spill, diversion, or
release of wastewater from or caused by the Sanitary Sewer System. This term
shall include: (i) discharges to waters of the State or United States from the
Sanitary Sewer System, and(ii) any release of wastewater from the Sanitary
Sewer System to public or private property that does not reach waters of the State
or United States.
z. "Section" shall mean a portion of this Decree identified by a Roman numeral.
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aa. "Service Area" shall mean a section of the Sewer System that is a distinct
drainage or wastewater collection area and designated as such by the City. For
purposes of this Consent Decree, the Service Areas are identified in the map
attached as Appendix 1 to this Consent Decree.
bb. "Sewer System"or"Sanitary Sewer System" shall mean the City's sanitary
wastewater collection and transmission system, including all pipes, interceptors,
Force Mains, Gravity Sewer Lines, Pumping Stations, manholes and
appurtenances thereto,that are owned or operated by the City. It does not include
private lateral lines not owned or operated by the City.
cc. "State" shall mean the State of Iowa.
dd. "United States" shall mean the United States of America, acting on behalf of
EPA.
ee. "Wastewater Treatment Plant"or"WWTP" shall mean any sewage treatment
plant(or water reclamation facility) operated by the City.
V. REMEDIAL MEASURES AND SCHEDULES
9. The City shall carry out assessments and engineering analyses necessary to
identify measures needed to ensure that its Sewer System and WWTPs comply with the
requirements of the CWA, applicable federal regulations and Iowa water pollution laws as
implemented through the City's NPDES Permit, and then shall implement all such measures in
accordance with the schedule contained in the Master Plan developed pursuant to Section V.H of
this Decree.
10. The City's plans, programs, and other submittals shall be based upon good
engineering practices and industry standards.
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11. The City hereby certifies that it has sufficient legal authority to:
a. Regulate volumes of wastewater from satellite municipalities and private sources;
b. Require that sewers and connections be properly designed and constructed;
c. Ensure that there is proper installation, testing and inspection of new and
rehabilitated sewers;
d. Allow and require implementation of the general and specific prohibitions of the
pretreatment program as defined in 40 C.F.R. § 403.5; and
e. Prohibit Inflow and provide mechanisms for requiring its removal.
12. Permits. Where any compliance obligation under this Section requires the City to
obtain a federal, state, or local permit or approval, the City shall submit timely and complete
applications and take all other actions necessary to obtain all such permits or approvals. The City
may seek relief under the provisions of Section XI of this Consent Decree (Force Majeure) for
any delay in the performance of any such obligation resulting from a failure to obtain, or a delay
in obtaining, any permit or approval required to fulfill such obligation, if the City has submitted
timely and complete applications and has taken all other actions necessary to obtain all such
permits or approvals.
A. Short-term Remedial Measures
13. SSO Signage. The City shall continue to post warning signs at all SSO sites to
the extent authorized by law. The signs shall be identical to Appendix 2 and shall stay in place
until occurrences of SSOs due to a lack of Adequate Capacity, or deficiencies in operations and
maintenance(O&M), at that location have been eliminated.
14. The City shall also continue to implement a targeted footing drain removal
program in Service Areas 15, 16, 18 and 19, as necessary to reduce SSOs, Building Backups, and
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Prohibited Bypasses occurring in those areas, consistent with the Capacity Assessment.
B. Capacity,Management, Operations,and Maintenance(CMOM) Program Plan
15. The City shall implement the CMOM Program Plan that has been reviewed and
accepted by EPA and IDNR.
16. The City shall biannually review its CMOM Program Plan and modify the Plan as
necessary to ensure that the CMOM Program Plan reflects current procedures and is achieving
the goals contained therein. Any substantive updates, changes or revisions to the CMOM
Program Plan, during the pendency of this agreement, shall be subject to EPA's review and
approval in accordance with Section VII(Review and Approval Procedures).
C. Sanitary Sewer Overflow Response Plan (SSORP)
17. The City shall implement the Sanitary Sewer Overflow Response Plan (SSORP)
that is attached as Appendix 4 to this Consent Decree. The SSORP shall be updated periodically
as appropriate. Any substantive updates, changes or revisions to the SSORP, during the
pendency of this agreement, shall be subject to EPA's review and approval in accordance with
Section VII (Review and Approval Procedures).
D. Rainfall and Flow Monitoring
18. The City shall use a network of rain gauge stations and flow monitors to carry out
additional dry and wet weather rainfall and flow monitoring as needed to complete and
implement the remedial measures described in this Section, and to ensure compliance with its
NPDES permit and the terms of this Consent Decree. The monitoring network shall be designed,
installed, operated and maintained to provide representative data of sufficient quality for use in
the development of the Hydraulic Model described in Section V.F, and the Capacity Assessment
described in Section V.G. Following completion of the Hydraulic Model and Capacity
Assessment,the City shall maintain a Long-Term Flow and Rainfall Monitoring program as part
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of its CMOM Program. The Long-Term Flow and Rainfall Monitoring program will be used to
investigate Service Areas for further flow monitoring and physical investigation activities, as
necessary, and shall be developed in accordance with Appendix 5.
E. Sewer System Condition Assessment
19. The City shall complete a targeted Condition Assessment of the Sewer System as
described in Appendix 6. The Condition Assessment shall identify portions of, and conditions
within, the Sewer System that contribute to SSOs, Building Backups, and Prohibited Bypasses.
The Condition Assessment shall be designed and implemented consistent with good engineering
practices and industry standards, and shall be used to develop the remedial measures in the
Master Plan described in Section V.H.
20. The Condition Assessment shall be completed, and the results reported, in
accordance with the schedule and reporting requirements contained in Appendix 6.
F. Hydraulic Model
21. The City shall develop an updated computerized hydraulic model of its Sanitary
Sewer System (Hydraulic Model) as described in Appendix 7. The calibrated Hydraulic Model
will be used to provide a sufficient understanding of the response of its Sanitary Sewer System to
wet weather events to enable the City to identify appropriate remedial measures to address
capacity limitations identified in its Sanitary Sewer System.
22. The Hydraulic Model shall be developed and initially calibrated to 2015 system
data no later than February 29, 2016. On or before that date, the City shall submit to EPA and
IDNR proof that the Hydraulic Model has been developed and initially calibrated.
23. A complete hydraulic modeling report will be submitted to EPA and IDNR by
August 31, 2016, in accordance with the format described in Appendix 7.
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G. Capacity Assessment
24. The City shall develop a Capacity Assessment of its Sewer System as described in
Appendix 8. The Capacity Assessment shall assess existing and future capacity of the Sanitary
Sewer System under a range of flows and rainfall events as identified in Appendix 8. The
Capacity Assessment shall account for existing conditions as well as projected population and
flow rate growth for twenty(20) years following the Effective Date.
25. The Capacity Assessment shall be completed, and the results reported, in
accordance with the schedule and reporting requirements contained in Appendix 8.
H. Sanitary Sewer Master Plan
26. No later than December 31, 2017, the City shall submit to EPA, with a copy to the
State, a Sanitary Sewer Master Plan(Master Plan) in accordance with the format described in
Appendix 9, for review and approval by EPA in accordance with the requirements of Section VII
(Review and Approval Procedures).
27. The Master Plan shall:
a. Present the results of the Condition Assessment described in Section V.E,the
Hydraulic Model described in Section V.F, and the Capacity Assessment
described in Section V.G;
b. Identify the specific remedial measures the City will undertake to address
significant structural issues in the Sanitary Sewer System, identified by the
Condition Assessment;
c. Identify the specific remedial measures the City will undertake to ensure that
there is Adequate Capacity in the Sanitary Sewer System, as defined by the
Capacity Assessment;
d. Provide a schedule for implementation of remedial measures in accordance with
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Paragraph 28, giving priority to actions which will address known SSOs, Building
Backups, and Prohibited Bypasses; and
e. Provide estimated capital, operation and maintenance, and present-value costs for
each identified remedial measure. Such costs shall be provided in consistent,
year-specific dollars.
28. Schedule of Remedial Measures.
a. The remedial measures in the Master Plan shall be completed no later than
December 31, 2032, unless that schedule is extended pursuant to Paragraphs 29 or
30.
b. For each remedial measure,the schedule in the Master Plan shall indicate the
designated 3-year time block in which the project will be completed, i.e. 2018-
2020, 2021-2023, 2024-2026, 2027-2029, 2030-2032. The City shall estimate
dates to complete initial design, start construction, complete construction, and
(where applicable) place into service.
c. In proposing the timing and order of remedial measures,the City shall set
priorities based upon potential for human health and environmental impact risks;
frequency and volume of SSOs, Building Backups, and Prohibited Bypasses; and
technical engineering judgment.
d. Upon approval of the Master Plan by EPA,the City shall implement the remedial
measures in the approved Master Plan in accordance with the schedule in the
Master Plan. The approved schedule shall be an enforceable part of this Consent
Decree.
e. The City may request that a remedial measure identified in the approved Master
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Plan be rescheduled from the 3-year designated grouping,to a later or earlier
designated 3-year grouping, provided that all necessary projects are completed by
the date specified in Paragraph 28.a.
i. Any request made pursuant to this sub-Paragraph shall be made in writing
pursuant to Paragraph 93, with copies to the State and all documentation
necessary to support the request for modification. Such request shall include
the specific remedial measure(s)to be moved to earlier/later years, an
explanation for the proposed modification, anticipated schedule for such
modification, and basis for the modification.
ii. Any other modifications to the approved Master Plan shall be in accordance
with Section XX (Modification).
29. If the City experiences significant adverse changes to its financial circumstances
or other financial or budgetary issues,the City may request a modification of the schedule in
Paragraph 28.a for completion of remedial measures. The request for modification shall be made
in writing to the United States, with a copy to the State, and shall:
a. Provide a detailed discussion of the significant adverse change to the City's
financial circumstances or other financial or budgetary issues;
b. Propose a revised schedule for completion of remedial measures; and
c. Include all documents and information supporting the request.
The City shall provide such additional information requested by the United States as is
reasonably necessary to assist in evaluating the modification request. If the Parties agree that the
City's financial condition has significantly deteriorated in comparison to when the Consent
Decree was entered, and agree on an appropriate modification to the schedule of corrective
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actions,that modification shall be incorporated into an amended consent decree that shall be
subject to court approval after public notice and comment in accordance with Section XXII
(Public Participation).
30. If the Parties do not agree that a modification proposal under Paragraph 29 is
warranted, and the City believes modification is appropriate,the City reserves its rights to file a
motion pursuant to Federal Rule of Civil Procedure 60(b) seeking modification of the schedule
for completion of remedial measures; provided, however,that the United States reserves its right
to oppose any such motion and to argue that such modification is unwarranted. Such a motion
by the City shall not relieve the City of its obligations pursuant to Section V(Remedial Measures
and Schedules), unless the Court orders otherwise, and the City shall continue with timely
implementation of the remedial measures until the Court rules on any motion described in this
paragraph in a manner that modifies the City's obligations under the Consent Decree.
VI. DEMONSTRATION AND ELIMINATION OF OVERFLOWS
31. Following completion of the remedial measures required by the Master Plan
(Section V.H) in accordance with the approved schedules, or at an earlier date if appropriate, the
City shall demonstrate for one year(the Demonstration Period)that SSOs, Building Backups,
and Prohibited Bypasses caused by a lack of Adequate Capacity of the Sanitary Sewer System,
or by deficiencies in operations and/or maintenance (O&M), have been eliminated.
32. If, prior to the end of the period for completion of remedial measures anticipated
by the Master Plan, the City concludes that it has made improvements sufficient to eliminate
SSOs, Building Backups, and Prohibited Bypasses caused by a lack of Adequate Capacity or by
deficiencies in O&M,the City may request to commence the one-year Demonstration Period at
that time. The City's request shall be submitted to EPA and IDNR in writing pursuant to
Ii
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Paragraph 93 and shall include the City's justification for commencing the Demonstration Period
at that earlier date. EPA, after consultation with IDNR, will respond to the City's request in
writing and, if EPA determines that the City has made improvements sufficient to achieve the
goal described above, will approve the City's request.
33. During the Demonstration Period, if the City experiences any SSOs,Building
Backups, or Prohibited Bypasses, the City shall report those events pursuant to Paragraph 93,
including an explanation of the causes of the incident and any measures the City will take to
prevent recurrence of any events caused by a lack of Adequate Capacity or deficiencies in O&M.
34. For SSOs, Building Backups, or Prohibited Bypasses caused by a lack of
Adequate Capacity of the Sanitary Sewer System, or by deficiencies in O&M, EPA may, where
warranted, notify the City that the City must prepare and submit a Remedial Plan and Schedule
(Remedial Plan)to EPA, for review and approval by EPA in accordance with the requirements of
Section VII(Review and Approval Procedures). When such a Remedial Plan is required:
a. The Remedial Plan shall include a schedule for completing the additional
measures proposed therein as expeditiously as possible. The City shall complete
the Remedial Plan in accordance with the approved schedule and in accordance
with sound engineering practices.
b. After completion of the projects in the Remedial Plan, the Demonstration Period
shall restart and the demonstration provisions of this Section shall again apply for
the full period of one year.
VII. REVIEW AND APPROVAL PROCEDURES
35. After review of any plan, report, or other item that is required to be submitted for
approval pursuant to this Consent Decree, EPA, after consultation with IDNR, shall in writing:
U.S. &State of Iowa v. City of Waterloo—Consent Decree—Page 19 of 51
a. approve the submission;
b. approve the submission upon specified conditions;
c. approve part of the submission and disapprove the remainder; or
d. disapprove the submission.
36. If the submission is approved pursuant to Paragraph 35.a,the City shall take all
actions required by the plan, report, or other document, in accordance with the schedules and
requirements of the plan, report, or other document, as approved. If the submission is
conditionally approved or approved only in part pursuant to Paragraph 35.b or c,the City shall,
upon written direction from EPA after consultation with IDNR,take all actions required by the
approved plan, report, or other item that EPA, after consultation with IDNR, determines are
technically severable from any disapproved portions, subject to the City's right to dispute only
the specified conditions or the disapproved portions, under Section XII(Dispute Resolution).
37. If the submission is disapproved in whole or in part pursuant to Paragraph 35.c or
d,the City shall, within forty-five (45) Days or such other time as the Parties agree to in writing,
correct all deficiencies and resubmit the plan, report, or other item, or disapproved portion
thereof, for approval, in accordance with the preceding Paragraphs. If the resubmission is
approved in whole or in part, the City shall proceed in accordance with the preceding Paragraph.
38. Any stipulated penalties applicable to the original submission, as provided in
Section X(Stipulated Penalties), shall accrue during the 45 Day period or other specified period,
but shall not be payable unless the resubmission is untimely or is disapproved in whole or in
part; provided that, if the original submission was so deficient as to constitute a material breach
of the City's obligations under this Decree,the stipulated penalties applicable to the original
submission shall be due and payable notwithstanding any subsequent resubmission.
U.S. &State of Iowa v. City of Waterloo-Consent Decree-Page 20 of 51
39. If a resubmitted plan, report, or other item, or portion thereof, is disapproved in
whole or in part, EPA, after consultation with IDNR, may again require the City to correct any
deficiencies, in accordance with the preceding Paragraphs, or may itself correct any deficiencies,
subject to the City's right to invoke dispute resolution and the right of the EPA to seek stipulated
penalties as provided in the preceding Paragraphs.
40. All plans, reports, and other items required to be submitted to EPA under this
Consent Decree shall, upon approval or modification by EPA, be enforceable under this Consent
Decree. In the event EPA approves or modifies a portion of a plan, report or other item required
to be submitted to EPA under this Consent Decree,the approved or modified portion shall be
enforceable under this Consent Decree, subject to the provisions of Section XII (Dispute
Resolution).
VIII. CIVIL PENALTY
41. The City shall pay a civil penalty of$272,000 as follows:
a. Within thirty(30) Days after the Effective Date, the City shall pay to the United
States the sum of$136,000 as a civil penalty, together with interest accruing from
the Date of Lodging, at the rate specified in 28 U.S.C. § 1961 as of the Date of
Lodging. The City shall pay the civil penalty due at https://www.pay.gov to the
U.S. Department of Justice account, in accordance with instructions provided to
the City by the Financial Litigation Unit("FLU") of the United States Attorney's
Office for the Northern District of Iowa after the Effective Date. The payment
instructions provided by the FLU shall include a Consolidated Debt Collection
System ("CDCS") number, which the City shall use to identify all payments
required to be made in accordance with this Consent Decree. The FLU will
U.S. &State of Iowa v. City of Waterloo—Consent Decree—Page 21 of 51
provide the payment instructions to:
Michelle Weidner,CPA
Chief Financial Officer
City of Waterloo
715 Mulberry Street
Waterloo, IA 50703
and
Mayor
City of Waterloo
715 Mulberry Street
Waterloo, IA 50703
on behalf of the City. The City may change the individual to receive payment
instructions on its behalf by providing written notice of such change to the United
States and EPA in accordance with Section XVI (Notices). At the time of
payment,the City shall send notice that payment has been made: (i)to EPA via
email at cinwd acctsreceivable@epa.gov or via regular mail at EPA Cincinnati
Finance Office, 26 W. Martin Luther King Drive, Cincinnati, Ohio 45268; (ii) to
the United States via email or regular mail in accordance with Section XVI; and
(iii) to EPA in accordance with Section XVI. Such notice shall state that the
payment is for the civil penalty owed pursuant to the Consent Decree in U.S. and
State of Iowa v. City of Waterloo, and reference the CDCS Number and DOJ case
number 90-5-1-1-10719.
b. In satisfaction of the State's share of the civil penalty,the City shall do one of the
following:
i. If the State, prior to December 11, 2015, authorizes and approves an
environmentally beneficial project or projects that meet the criteria set forth
in Appendix 3,then the City shall perform such project or projects in
U.S. &State of Iowa v. City of Waterloo—Consent Decree—Page 22 of 51
accordance with the terms and schedule approved by the State; or
ii. If, by December 11, 2015, the State has not approved an environmentally
beneficial project which meets the criteria in Appendix 3, the City shall pay
the sum of$136,000 to the State as a civil penalty by mailing a check
payable to the"State of Iowa"to:
David Steward
Environmental Law Division
Lucas State Office Bldg.
321 E. 12th Street, Room 018
Des Moines, IA 50319
iii. If, prior to December 11, 2015, the State has authorized and approved
projects that meet the criteria in Appendix 3, but the total cost to the City of
those projects is less than $136,000,the City shall pay the difference to the
State as a civil penalty in accordance with the procedure described above.
42. The City shall not deduct any penalties paid under this Decree pursuant to this
Section or Section X (Stipulated Penalties) in calculating its federal or State income tax.
IX. REPORTING REQUIREMENTS
43. The City shall submit a Status Report to EPA and IDNR annually on December
31 until termination of this Consent Decree as described in Section XXI (Termination). Each
Status Report submitted on December 31 shall cover events from October of the prior Calendar
Year through September of the present Calendar Year.
44. Each Status Report shall contain a summary of the progress, since the previous
Status Report, and current status of all projects, plans, and programs discussed in Section V
(Remedial Measures and Schedules). This summary will include, but is not limited to:
a. A description of completed activities since the previous Status Report that are
U.S. &State of Iowa v. City of Waterloo—Consent Decree—Page 23 of 51
associated with the Condition Assessment, Hydraulic Model, Capacity
Assessment, approved Sanitary Sewer Master Plan, and CMOM program;
b. A summary of any planned activities to occur in the time period before the next
Status Report;
c. An explanation of any updates or changes to existing projects, plans, and
programs since the previous Status Report; and
d. Any conditions, including financial conditions, that the City anticipates may result
in a delay in meeting the designated submission deadlines for any work products
identified in this Consent Decree.
45. When, consistent with its NPDES Permit, the City submits its monthly"Bypass,
SSO, and Basement Back-up Report"and its Monthly Operating Reports (MORs)to IDNR, the
City shall simultaneously provide a courtesy copy of those reports to EPA via the procedure
described in Section XVI (Notices).
46. Whenever any violation of this Consent Decree, or any other event affecting the
City's performance under this Decree, may pose an immediate threat to the public health or
welfare or the environment,the City shall notify EPA and the State orally or by electronic mail
as soon as possible, but no later than 24 hours after the City first knew of the violation or event.
This procedure is in addition to the requirements set forth in the preceding Paragraph.
47. All reports shall be submitted to the persons designated in Section XVI (Notices).
48. All reports required to be submitted in this Section shall contain a certification
signed by a responsible official of the City in accordance with Paragraph 96.
49. The City shall maintain copies of all written submissions prepared pursuant to this
Section for five years after termination of the Decree.
U.S. &State of Iowa v. City of Waterloo—Consent Decree—Page 24 of 51
50. The reporting requirements of this Consent Decree do not relieve the City of any
reporting obligations required by the CWA or implementing regulations, or by any other federal,
state, or local law, regulation, permit, or other requirement.
51. Any information provided pursuant to this Consent Decree may be used by the
United States or the State in any proceeding to enforce the provisions of this Consent Decree and
as otherwise permitted by law. The City shall not object to the admissibility into evidence of any
report, plan, notice, or any other document prepared in accordance with this Consent Decree or
the information contained in said reports in any proceeding to enforce this Consent Decree.
X. STIPULATED PENALTIES
52. The City shall be liable for stipulated penalties to the United States and the State
for violations of this Consent Decree as specified below, unless excused under Section XI (Force
Majeure). A violation includes failing to perform any obligation required by the terms of this
Decree, including any work plan or schedule approved under this Decree, according to all
applicable requirements of this Decree and within the specified time schedules established by or
approved under this Decree.
53. Failure to Submit Timely and Complete Documents. The City shall pay
stipulated penalties to be split between the United States and the State, as set forth below, for
each Day it fails to submit a timely or complete report or other submittal required under Section
V of this Consent Decree (Remedial Measures and Schedules), and/or appendices of this Consent
Decree. "Timely" shall mean the report or submittal is made by the date specified in this
Consent Decree, including appendices, and"complete" shall mean that the report or submittal
includes all of the elements pertaining to the report or submittal as set forth in this Consent
Decree, including appendices.
U.S. &State of Iowa v. City of Waterloo—Consent Decree—Page 25 of 51
Period of Noncompliance Penalty per Violation per Day
1st to 30th Day $200.00
31st to 60th Day $400.00
more than 60 Days $600.00
54. Remedial Requirements. The City shall pay stipulated penalties to the United
States and the State as set forth below for each Day the City fails to satisfy any of the remedial
requirements of Section V (Remedial Measures and Schedules). The stipulated penalties for
failure to meet each such requirement shall be as follows:
Period of Noncompliance Penalty per Violation per Day
1st to 30th Day $500.00
31st to 60th Day $1000.00
more than 60 Days $2000.00
55. SSOs and Prohibited Bypasses. Subject to the exceptions noted in Paragraph
55.c, for each SSO or Prohibited Bypass that(a)reaches waters of the United States or waters of
the State, and (b) that is the result of a lack of Adequate Capacity or deficiencies in O&M, the
City shall pay stipulated penalties to the United States and the State as follows:
a. For each such SSO or Prohibited Bypass occurring during the period from
the Date of Lodging through the completion of the remedial measures
required by Section V (Remedial Measures and Schedules), the City shall
pay a stipulated penalty as follows:
If SSO or Prohibited Bypass occurs in Penalty per Violation per Day
Prior to approval of Master Plan $0
From approval of Master Plan through Calendar Year 2020 $200.00
U.S. &State of Iowa v. City of Waterloo—Consent Decree—Page 26 of 51
Calendar Years 2021 through 2023 $400.00
Calendar Years 2024 through 2026 $600.00
Calendar Years 2027 through 2029 $800.00
Calendar Years 2030 through 2032 $1000.00
b. For each such SSO or Prohibited Bypass occurring after completion of the
remedial measures required by Section V (Remedial Measures and
Schedules), the City shall pay$2,000.00 per violation per Day.
c. The City shall not be liable for stipulated penalties under this Paragraph if:
i. The SSO or Prohibited Bypass was caused by flood conditions(defined as a
Cedar River gage height of 13 feet or greater at the 6th Street gage in
Waterloo, or a Black Hawk Creek gage height of 14 feet or greater at the
gage in Hudson); and/or
ii. The City experiences an SSO or Prohibited Bypass and fully complies with
the terms of the Standard Conditions in its NPDES Permit(e.g., Standard
Condition Part 23(b)(ii)(1)-(3)).
56. Reportin2 Requirements. The City shall pay stipulated penalties to the United
States and the State for each Day for each violation of the reporting requirements of Section IX
(Reporting Requirements) as follows:
Period of Noncompliance Penalty Per Violation Per Day
1st through 30th Day $200.00
31 St through 60th Day $400.00
more than 60 Days $600.00
57. Delay in Payment of Penalty: If the City fails to pay the civil penalty required to
U.S. &State of Iowa v. City of Waterloo—Consent Decree—Page 27 of 51
be paid under Section VIII (Civil Penalty) when due, the City shall pay a stipulated penalty of
$1,000 per Day for each Day that the payment is late.
58. Stipulated penalties under this Section shall begin to accrue on the Day after
performance is due or on the Day a violation occurs, whichever is applicable, and shall continue
to accrue until performance is satisfactorily completed or until the violation ceases. Stipulated
penalties shall accrue simultaneously for separate violations of this Consent Decree.
59. The City shall pay stipulated penalties to the United States and the State within
thirty(30) Days of a written demand by either Plaintiff, unless the City invokes the dispute
resolution procedures under Section XII (Dispute Resolution)within the 30-day period. The
City shall pay 50% of the total stipulated penalty amount due to the United States and 50%to the
State. The Plaintiff making a demand for payment of a stipulated penalty shall simultaneously
send a copy of the demand to the other Plaintiff.
60. Either Plaintiff may in the unreviewable exercise of its discretion, reduce or waive
stipulated penalties otherwise due to that Plaintiff under this Consent Decree.
61. Stipulated penalties shall continue to accrue as provided in Paragraph 58, during
any dispute resolution, but need not be paid until the following:
a. If the dispute is resolved by agreement of the Parties,the City shall pay accrued
penalties agreed to be owing,together with interest, to the Plaintiffs within thirty
(30)Days of the effective date of the agreement. If the dispute is resolved by a
decision of EPA or the State that is not appealed to the Court,the City shall pay
accrued penalties determined to be owing,together with interest, to the Plaintiffs
within thirty(30) Days of the effective date of the agreement or the receipt of
EPA's or the State's decision or order.
U.S. &State of Iowa v. City of Waterloo—Consent Decree—Page 28 of 51
b. If the dispute is appealed to the Court and the United States or the State prevails
in whole or in part, the City shall pay any accrued penalties determined by the
Court to be owing, together with interest, within sixty(60) Days of receiving the
Court's decision or order, except as provided in Paragraph 61.c, below.
c. If any Party appeals the District Court's decision, the City shall pay any accrued
penalties determined by the Court to be owing,together with interest, within
fifteen (15) Days of receiving the final appellate court decision.
62. The City shall pay stipulated penalties owing to the Plaintiffs in the manner set
forth and with the confirmation notices required by Section VIII(Civil Penalty), except that the
transmittal letters shall state that the payment is for stipulated penalties and shall state for which
violation(s)the penalties are being paid.
63. If the City fails to pay stipulated penalties according to the terms of this Consent
Decree, the City shall be liable for interest on such penalties, as provided for in 28 U.S.C.
§ 1961, accruing as of the date payment became due. Nothing in this Paragraph shall be
construed to limit the United States or the State from seeking any remedy otherwise provided by
law for the City's failure to pay any stipulated penalties.
64. The payment of penalties and interest, if any, shall not alter in any way the City's
obligation to complete the performance of the requirements of this Consent Decree.
65. Stipulated penalties are not the Plaintiffs' exclusive remedy for violations of this
Consent Decree. Subject to the provisions of Section XIV (Effect of Settlement/Reservation of
Rights), the Plaintiffs expressly reserve the right to seek any other relief deemed appropriate for
the City's violation of this Decree or applicable law, including but not limited to an action
against the City for statutory penalties, additional injunctive relief, mitigation or offset measures,
U.S. &State of Iowa v. City of Waterloo—Consent Decree—Page 29 of 51
and/or contempt. However, the amount of any statutory penalty assessed for a violation of this
Consent Decree shall be reduced by an amount equal to the amount of any stipulated penalty
assessed and paid pursuant to this Consent Decree.
XI. FORCE MAJEURE
66. "Force majeure," for purposes of this Consent Decree, is defined as any event
arising from causes beyond the control of the City, of any entity controlled by the City, or of the
City's contractors, which delays or prevents the performance of any obligation under this
Consent Decree despite the City's best efforts to fulfill the obligation. The requirement that the
City exercise"best efforts to fulfill the obligation" includes using best efforts to anticipate any
potential force majeure event and best efforts to address the effects of any such event(a) as it is
occurring and(b) following the potential force majeure, such that the delay and any adverse
effects of the delay are minimized. "Force majeure"does not include the City's financial
inability to perform any obligation under this Consent Decree, unanticipated or increased
expenses or costs associated with implementation of this Consent Decree, changed financial
circumstances, or other financial or budgetary issues.
67. If any event occurs or has occurred that may delay the performance of any
obligation under this Consent Decree, for which the City intends or may intend to assert a claim
of force majeure, the City shall provide notice orally or by electronic mail to EPA and IDNR,
within 72 hours of when the City first knew that the event might cause a delay. Within seven (7)
Days thereafter, the City shall provide in writing to EPA and IDNR, in accordance with Section
XVI(Notices), an explanation and description of the reasons for the delay; the anticipated
duration of the delay; all actions taken or to be taken to prevent or minimize the delay; a
schedule for implementation of any measures to be taken to prevent or mitigate the delay or the
U.S. &State of Iowa v. City of Waterloo—Consent Decree-Page 30 of 51
effect of the delay; the City's rationale for attributing such delay to a force majeure event if it
intends to assert such a claim; and a statement as to whether, in the opinion of the City, such
event may cause or contribute to an endangerment to public health, welfare or the environment.
The City shall include with any notice all available documentation supporting the claim that the
delay was attributable to a force majeure. The City shall be deemed to know of any
circumstance of which the City, any entity controlled by the City, or the City's contractors knew
or should have known. Failure to comply with the above requirements regarding an event
precludes the City from asserting any claim of force majeure regarding that event, provided,
however, that if EPA, despite the late notice, is able to assess to its satisfaction whether the event
is a force majeure event under Paragraph 66 and whether the City has exercised best efforts
under Paragraph 66, EPA, after consultation with the State, may, in its unreviewable discretion,
excuse in writing the City's failure to submit timely notices under this Paragraph.
68. If EPA, after a reasonable opportunity for review and comment by the State,
agrees that the delay or anticipated delay is attributable to a force majeure event,the time for
performance of the obligations under this Consent Decree that are affected by the force majeure
event will be extended by EPA, after a reasonable opportunity for review and comment by the
State, for such time as is necessary to complete those obligations. An extension of the time for
performance of the obligations affected by the force majeure event shall not, of itself, extend the
time for performance of any other obligation. EPA will notify the City in writing of the length of
the extension, if any, for performance of the obligations affected by the force majeure event.
69. If EPA, after a reasonable opportunity for review and comment by the State, does
not agree that the delay or anticipated delay has been or will be caused by a force majeure event,
EPA will notify the City in writing of its decision. The United States' position shall be binding,
U.S. &State of Iowa v. City of Waterloo—Consent Decree—Page 31 of 51
unless the City invokes dispute resolution under Section XII (Dispute Resolution).
70. If the City elects to invoke the dispute resolution procedures set forth in Section
XII (Dispute Resolution), it shall do so no later than thirty(30) Days after receipt of EPA's
notice. In any such proceeding, the City shall have the burden of demonstrating by a
preponderance of the evidence that the delay or anticipated delay has been or will be caused by a
force majeure event, that the duration of the delay or the extension sought was or will be
warranted under the circumstances,that best efforts were exercised to avoid and mitigate the
effects of the delay, and that the City complied with the requirements of Paragraphs 66 and 67.
If the City carries this burden,the delay at issue shall be deemed not to be a violation by the City
of the affected obligation of this Consent Decree identified to EPA and the Court.
XII. DISPUTE RESOLUTION
71. Unless otherwise expressly provided for in this Consent Decree, the dispute
resolution procedures of this Section shall be the exclusive mechanism to resolve disputes arising
under or with respect to this Consent Decree. The City's failure to seek resolution of a dispute
under this Section shall preclude the City from raising any such issue as a defense to an action by
the Plaintiffs to enforce any obligation of the City arising under this Consent Decree. This
Section does not apply to disputes between the City and the State of Iowa(or its agencies and
subdivisions)regarding permits and/or regulatory compliance.
72. Informal Dispute Resolution Between Plaintiffs and City. Any dispute subject
to dispute resolution under this Consent Decree shall first be the subject of informal negotiations.
The dispute shall be considered to have arisen when the City sends the Plaintiffs a written Notice
of Dispute. Such Notice of Dispute shall state clearly the matter in dispute. The period of
informal negotiations shall not exceed twenty(20) Days from the date the dispute arises, unless
U.S. &State of Iowa v. City of Waterloo—Consent Decree-Page 32 of 51
that period is modified by written agreement. If the Parties cannot resolve a dispute by informal
negotiations, then the position advanced by the United States, after consultation with the State,
shall be considered binding unless, within thirty(30)Days after the conclusion of the informal
negotiation period, the City invokes formal dispute resolution procedures as set forth below.
73. Formal Dispute Resolution Between Plaintiffs and City. The City shall invoke
formal dispute resolution procedures, within the time period provided in the preceding
Paragraph, by serving on the Plaintiffs a written Statement of Position regarding the matter in
dispute. The Statement of Position shall include, but need not be limited to, any factual data,
analysis, or opinion supporting the City's position and any supporting documentation relied upon
by the City.
74. The United States, after consultation with the State, shall serve its Statement of
Position within thirty(30) Days of receipt of the City's Statement of Position. The United
States' Statement of Position shall include, but need not be limited to, any factual data, analysis,
or opinion supporting that position and any supporting documentation relied upon by the United
States. The United States' Statement of Position shall be binding on the City, unless the City
files a motion for judicial review of the dispute in accordance with the following Paragraph.
75. The City may seek judicial review of the dispute by filing with the Court and
serving on the Plaintiffs, in accordance with Section XVI (Notices), a motion requesting judicial
resolution of the dispute. The motion must be filed within twenty (20) Days of receipt of the
United States' Statement of Position pursuant to the preceding Paragraph. The motion shall
contain a written statement of the City's position on the matter in dispute, including any
supporting factual data, analysis, opinion, or documentation, and shall set forth the relief
requested and any schedule within which the dispute must be resolved for orderly
U.S. &State of Iowa v. City of Waterloo—Consent Decree—Page 33 of 51
implementation of the Consent Decree.
76. The United States, after consultation with the State, shall respond to the City's
motion within the time period allowed by the Local Rules of this Court. The City may file a
reply memorandum,to the extent permitted by the Local Rules.
77. Judicial Review of Disputes. Except as otherwise provided in this Consent
Decree, in any dispute brought under Paragraph 73, the United States reserves the right to argue
that its position is reviewable only on the administrative record and must be upheld unless
arbitrary and capricious or otherwise not in accordance with law, and the City reserves the right
to oppose this position. If the United States does not so argue, or if the Court finds that the
arbitrary and capricious standard does not apply,the City shall bear the burden of proving that its
actions were in compliance with this Consent Decree; or, if the dispute concerns the
interpretation of this Consent Decree, the City shall bear the burden of demonstrating that its
position complies with this Decree.
78. The invocation of dispute resolution procedures under this Section shall not, by
itself, extend, postpone, or affect in any way any obligation of the City under this Consent
Decree, unless and until final resolution of the dispute so provides. Stipulated penalties with
respect to the disputed matter shall continue to accrue from the first Day of noncompliance, but
payment shall be stayed pending resolution of the dispute as provided in Paragraph 61. If the
City does not prevail on the disputed issue, stipulated penalties shall be assessed and paid as
provided in Section X (Stipulated Penalties).
XIII. INFORMATION COLLECTION AND RETENTION
79. The United States,the State, and their representatives, including attorneys,
contractors, and consultants, shall have the right of entry into the premises of any City property,
U.S. &State of Iowa v. City of Waterloo—Consent Decree—Page 34 of 51
at all reasonable times, upon presentation of credentials,to:
a. monitor the progress of activities required under this Consent Decree;
b. verify any data or information submitted to the United States or the State in
accordance with the terms of this Consent Decree;
c. obtain samples and, upon request, splits of any samples taken by the City or its
representatives, contractors, or consultants;
d. observe performance tests;
e. obtain documentary evidence, including photographs and similar data; and
f. assess the City's compliance with this Consent Decree.
80. Until five years after the termination of this Consent Decree,the City shall retain,
and shall instruct its contractors and agents to preserve, copies of any reports, plans,permits, and
documents submitted to the United States and/or the State pursuant to this Consent Decree, as
well as any underlying research and data used to develop such submittals (hereinafter referred to
as "Records"). This information-retention requirement applies regardless of any contrary City,
corporate or institutional policies or procedures. At any time during this information-retention
period, upon request by the United States or the State, the City shall provide copies of any
Records required to be maintained under this Paragraph.
81. At the conclusion of the information-retention period provided in the preceding
Paragraph,the City shall notify the United States and the State at least ninety(90)Days prior to
the destruction of any Records subject to the requirements of the preceding Paragraph and, upon
request by the United States or the State,the City shall deliver any such Records to EPA or
IDNR.
82. Privileged and Business Confidential Documents. In response to a request for
U.S. &State of Iowa v. City of Waterloo—Consent Decree—Page 35 of 51
Records pursuant to Paragraph 80 or 81,
a. The City may assert that all or part of a Record is privileged or protected as
provided under federal law. If the City asserts such a privilege, it shall provide
the following: (1)the title of the Record; (2)the date of the Record; (3)the name
and title of each author of the Record; (4)the name and title of each addressee and
recipient; (5) a description of the contents of the Record; and (6)the privilege or
protection asserted by the City. If a claim of privilege or protection applies only
to a portion of a Record, the Record shall be provided to EPA or IDNR in
redacted form to mask the privileged or protected portion only. The City shall
retain all Records that it claims to be privileged or protected until EPA has had a
reasonable opportunity to dispute the privilege or protection claim and any such
dispute has been resolved in the City's favor.
b. The City may also assert business confidentiality claims covering part or all of the
Records required to be provided under this Section to the extent permitted by and
in accordance with 40 C.F.R. § 2.203(b). Records determined to be confidential
by EPA will be afforded the protection specified in 40 C.F.R. Part 2, Subpart B. If
no claim of confidentiality accompanies Records when they are submitted to EPA
and IDNR, or if EPA has notified the City that the Records are not confidential
under the standards of 40 C.F.R. Part 2, Subpart B, the public may be given
access to such Records without further notice to the City.
c. The City may make no claim of business confidentiality, privilege or protection
regarding finalized versions of any Records that the City is required to create or
generate pursuant to this Consent Decree.
U.S. &State of Iowa v. City of Waterloo—Consent Decree—Page 36 of 51
83. This Consent Decree in no way limits or affects any right of entry and inspection,
or any right to obtain information, held by the United States or the State pursuant to applicable
federal or state laws, regulations, or permits, nor does it limit or affect any duty or obligation of
the City to maintain documents, records, or other information imposed by applicable federal or
state laws, regulations, or permits.
XIV. EFFECT OF SETTLEMENT/RESERVATION OF RIGHTS
84. This Consent Decree resolves the civil claims of the United States and the State
for the violations alleged in the Complaint filed in this action through the Date of Lodging.
85. The United States and the State reserve all rights against the City with respect to
any violations by the City that occur after the Date of Lodging, and/or for any violations of the
CWA or applicable state law not specifically alleged in the Complaint, whether they occurred
before or after the Date of Lodging.
86. The United States and the State further reserve all legal and equitable remedies
available to enforce the provisions of this Consent Decree. This Consent Decree shall not be
construed to limit the rights of the United States or the State to obtain penalties or injunctive
relief under the CWA or implementing regulations, or under other federal or state laws,
regulations, or permit conditions, except as expressly specified in Paragraphs 84 and 85. The
United States and the State reserve all rights against the City with respect to criminal liability.
The United States and the State further reserve all legal and equitable remedies to address any
imminent and substantial endangerment to the public health or welfare or the environment
arising at, or posed by, the City's publicly owned treatment works, whether related to the
violations addressed in this Consent Decree or otherwise.
87. In any subsequent administrative or judicial proceeding initiated by the United
U.S. &State of Iowa v. City of Waterloo—Consent Decree—Page 37 of 51
States or the State for injunctive relief, civil penalties, or other appropriate relief relating to the
City's publicly owned treatment works,the City shall not assert, and may not maintain, any
defense or claim based upon the principles of waiver, res judicata, collateral estoppel, issue
preclusion, claim preclusion, claim-splitting, or other defenses based upon any contention that
the claims raised by the United States or the State in the subsequent proceeding were or should
have been brought in the instant case, except with respect to claims that have been specifically
resolved pursuant to Paragraph 84.
88. This Consent Decree is not and shall not be construed as a permit or a
modification of any permit, under any federal, State, or local laws or regulations. The City is
responsible for achieving and maintaining complete compliance with all applicable federal,
State, and local laws, regulations, and permits; and the City's compliance with this Consent
Decree shall be no defense to any action commenced pursuant to any such laws, regulations, or
permits, except as set forth herein. The United States and the State do not, by their consent to the
entry of this Consent Decree, warrant or aver in any manner that the City's compliance with any
aspect of this Consent Decree will result in compliance with provisions of the CWA or with any
other provisions of federal, State, or local laws, regulations, or permits. Notwithstanding EPA
and IDNR's review or approval of any plans, reports, policies or procedures developed pursuant
to or as a result of this Consent Decree, the City shall remain solely responsible for any non-
compliance with the terms of this Consent Decree, all applicable permits, as well as all federal
and State laws and regulations promulgated under those laws.
89. Application for construction grants, State Revolving Loan Funds, or any other
grants or loans, or other delays caused by inadequate facility planning or plans and specifications
on the part of the City shall not be cause for extension of any required compliance date in this
U.S. &State of Iowa v. City of Waterloo—Consent Decree—Page 38 of 51
Consent Decree. Nothing in this Consent Decree limits the rights or defenses available under
Section 309(e)of the CWA, 33 U.S.C. § 1319(e), in the event that the laws of the State, as
currently or hereafter enacted, may prevent the City from raising the revenues needed to comply
with this Decree.
90. This Consent Decree does not limit or affect the rights of the Parties against any
third parties, not party to this Consent Decree, nor does it limit the rights of third parties, not
party to this Consent Decree, against the City, except as otherwise provided by law.
91. This Consent Decree shall not be construed to create rights in, or grant any cause
of action to, any third party not party to this Consent Decree.
XV. COSTS
92. The Parties shall bear their own costs of this action, including attorneys' fees,
except that the United States and the State shall be entitled to collect the costs (including
attorneys' fees) incurred in any action necessary to collect any portion of the civil penalty or any
stipulated penalties due but not paid by the City.
XVI. NOTICES
93. Unless otherwise specified in this Decree, whenever notifications, submissions, or
communications are required by this Consent Decree,they shall be made in writing and
addressed as follows:
As to the United States by email: eescasemanagement.enrd(a�usdoj.gov
Re: DJ# 90-5-1-1-10719
As to the United States by mail: EES Case Management Unit
Environment and Natural Resources Division
U.S. Department of Justice
P.O. Box 7611
Washington, DC 20044-7611
Re: DJ# 90-5-1-1-10719
U.S. &State of Iowa v. City of Waterloo—Consent Decree—Page 39 of 51
As to EPA: Chief, Water Enforcement Branch
Water, Wetlands, and Pesticides Division
U.S. Environmental Protection Agency, Region 7
11201 Renner Blvd.
Lenexa, KS 66219
and
Chris Muehlberger
Office of Regional Counsel
U.S. Environmental Protection Agency, Region 7
11201 Renner Blvd.
Lenexa, KS 66219
As to the State: David Steward
Environmental Law Division
Iowa Department of Justice
Lucas State Office Building
321 East 12th Street, Room 018
Des Moines, IA 50319
As to IDNR: Joseph Sanfilippo
Environmental Program Supervisor
Iowa Department of Natural Resources
909 West Main, Suite 4
Manchester, IA 52057
As to the City: Michelle Weidner, CPA
Chief Financial Officer
City of Waterloo
715 Mulberry Street
Waterloo, IA 50703
and
Mayor
City of Waterloo
715 Mulberry Street
Waterloo, IA 50703
94. Any Party may, by written notice to the other Parties, change its designated notice
recipient or notice address provided above.
95. Notices submitted pursuant to this Section shall be deemed submitted upon
U.S. &State of Iowa v. City of Waterloo—Consent Decree—Page 40 of 51
mailing, unless otherwise provided in this Consent Decree or by mutual agreement of the Parties
in writing.
XVII. CERTIFICATION
96. Each report, plan, notice, or any other document submitted by the City to the
United States or the State pursuant to this Consent Decree shall be signed by an official of the
City and include the following 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 inquiry of the person or persons 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 have no personal knowledge that the
information submitted is other than 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.
97. This certification requirement does not apply to emergency or similar
notifications where compliance would be impractical.
XVIII. EFFECTIVE DATE
98. The Effective Date of this Consent Decree shall be the date upon which this
Consent Decree is entered by the Court or a motion to enter the Consent Decree is granted,
whichever occurs first, as recorded on the Court's docket.
XIX. RETENTION OF JURISDICTION
99. The Court shall retain jurisdiction over this case until termination of this Consent
Decree, for the purpose of resolving disputes arising under this Decree or entering orders
modifying this Decree, pursuant to Sections XII(Dispute Resolution) and XX (Modification), or
effectuating or enforcing compliance with the terms of this Decree.
U.S. &State of Iowa v. City of Waterloo—Consent Decree—Page 41 of 51
XX. MODIFICATION
100. The terms of this Consent Decree, including any attached appendices, may be
modified only by a subsequent written agreement signed by all the Parties or by further order of
the Court. Where a modification agreed upon by the Parties constitutes a material change to this
Consent Decree, it shall be effective only upon approval by the Court.
101. The Parties may by mutual agreement determine whether a modification is non-
material. Non-material changes to this Consent Decree (including appendices) shall be made by
written agreement of the Parties without Court approval. Non-material changes that require
written agreement of the Parties include changes in remedial measures included in the Master
Plan (Section V.H), which modify overall project scope or reschedule the 3-year time block in
which the measures were originally scheduled for completion, so long as those changes do not
adversely affect conformance with Consent Decree performance objectives or final completion
deadlines. Any scheduling change which would delay the final completion of remedial measures
beyond the 15-year deadline established in Paragraph 28.a shall constitute a material
modification requiring Court approval.
102. Any disputes concerning modification of this Consent Decree shall be resolved
pursuant to Section XII(Dispute Resolution), provided, however, that, instead of the burden of
proof provided by Paragraph 77, the Party seeking the modification bears the burden of
demonstrating that it is entitled to the requested modification in accordance with Federal Rule of
Civil Procedure 60(b).
XXI. TERMINATION
103. After the City has completed the requirements of Paragraphs 13 through 27 and
Section VI (Demonstration and Elimination of Overflows), and has paid the civil penalties and
U.S. &State of Iowa v. City of Waterloo—Consent Decree—Page 42 of 51
any accrued stipulated penalties as required by this Consent Decree, the City may serve upon the
United States and the State a Request for Termination, stating that the City has satisfied those
requirements, together with all necessary supporting documentation.
104. Following receipt by the United States and the State of the City's Request for
Termination, the Parties shall confer informally concerning the Request and any disagreement
that the Parties may have as to whether the City has satisfactorily complied with the
requirements for termination of this Consent Decree. If the United States after consultation with
the State agrees that the Consent Decree may be terminated,the Parties shall submit, for the
Court's approval, a joint stipulation terminating the Consent Decree.
105. If the United States after consultation with the State determines that the Consent
Decree cannot be terminated,the City may invoke dispute resolution under Section XII (Dispute
Resolution). However, the City shall not seek dispute resolution of any dispute regarding
termination until at least 120 Days after service of its Request for Termination. This Consent
Decree shall remain in effect pending resolution of the dispute by the Parties or the Court in
accordance with the provisions of Section XII(Dispute Resolution).
XXII. PUBLIC PARTICIPATION
106. This Consent Decree shall be lodged with the Court for a period of not less than
thirty(30) Days for public notice and comment in accordance with 28 C.F.R. § 50.7. The United
States reserves the right to withdraw or withhold its consent if the comments regarding the
Consent Decree disclose facts or considerations indicating that the Consent Decree is inappro-
priate, improper, or inadequate. The City consents to entry of this Consent Decree without
further notice and agrees not to withdraw from or oppose entry of this Consent Decree by the
Court or to challenge any provision of the Consent Decree, unless the United States has notified
U.S. &State of Iowa v. City of Waterloo—Consent Decree—Page 43 of 51
the City in writing that it no longer supports entry of the Consent Decree.
XXIII. SIGNATORIES/SERVICE
107. Each undersigned representative of the City and the State, and the Assistant
Attorney General for the Environment and Natural Resources Division of the Department of
Justice, certifies that he or she is fully authorized to enter into the terms and conditions of this
Consent Decree and to execute and legally bind the Party he or she represents to this document.
108. This Consent Decree may be signed in counterparts, and its validity shall not be
challenged on that basis. The City agrees to accept service of process by mail with respect to all
matters arising under or relating to this Consent Decree and to waive the formal service
requirements set forth in Rules 4 and 5 of the Federal Rules of Civil Procedure and any
applicable Local Rules of this Court including, but not limited to, service of a summons.
XXIV. INTEGRATION
109. This Consent Decree and its appendices constitute the final, complete, and
exclusive agreement and understanding among the Parties with respect to the settlement
embodied in the Consent Decree and supersedes all prior agreements and understandings,
whether oral or written, concerning the settlement embodied herein. Other than Deliverables that
are subsequently submitted and approved pursuant to this Consent Decree, the Parties
acknowledge that there are no representations, agreements, or understandings relating to the
settlement other than those expressly contained in this Decree.
XXV. FINAL JUDGMENT
110. Upon approval and entry of this Consent Decree by the Court, this Consent
Decree shall constitute a final judgment of the Court as to the United States,the State, and the
City.
U.S. &State of Iowa v. City of Waterloo—Consent Decree—Page 44 of 51
XXVI. APPENDICES
111. The following appendices are attached to and incorporated into this Consent
Decree:
Appendix 1 —map of Service Areas
Appendix 2— SSO signage
Appendix 3 —Criteria for Environmentally Beneficial Project Selection
Appendix 4— Sanitary Sewer Overflow Response Plan
Appendix 5 —Long-Term Flow&Rainfall Monitoring Program
Appendix 6—Sanitary Sewer System Condition Assessment
Appendix 7—Hydraulic Model
Appendix 8— Sanitary Sewer System Capacity Assessment
Appendix 9—Sanitary Sewer Master Plan
Dated and entered this day of , 2015.
UNITED STATES DISTRICT JUDGE
U.S. &State of Iowa v. City of Waterloo—Consent Decree—Page 45 of 51
THE UNDERSIGNED PARTIES enter into this Consent Decree in the matter of United States
and State of Iowa v. City of Waterloo.
FOR THE UNITED STATES OF AMERICA:
Dated JOHN C. CRUDEN
Assistant Attorney General
Environment and Natural Resources Division
U.S. Department of Justice
Washington, D.C.
Dated DANICA ANDERSON GLASER
Trial Attorney
Environmental Enforcement Section
Environment and Natural Resources Division
U.S. Department of Justice
P.O. Box 7611, Ben Franklin Station
Washington, D.C. 20044-7611
Tel.: (202) 514-5270
Fax: (202) 514-0097
danica.glaserna usdoj.gov
U.S. &State of Iowa v. City of Waterloo—Consent Decree—Page 46 of 51
THE UNDERSIGNED PARTIES enter into this Consent Decree in the matter of United States
and State of Iowa v. City of Waterloo.
KEVIN W. TECHAU
United States Attorney
Northern District of Iowa
Dated MATTHEW J. COLE
Chief of the Civil Division
U.S.Attorney's Office
Northern District Of Iowa
111 7th Avenue, SE
Box#1
Cedar Rapids, IA 52401
Phone: (319) 363-6333
Cedar Rapids Fax Line: (319) 363-1990
Cedar Rapids TTY Line: (319) 286-9258
U.S. &State of Iowa v. City of Waterloo—Consent Decree—Page 47 of 51
THE UNDERSIGNED PARTIES enter into this Consent Decree in the matter of United States
and State of Iowa v. City of Waterloo.
Dated MARK POLLINS
Division Director
Water Enforcement Division
Office of Civil Enforcement
Office of Enforcement and Compliance Assurance
United States Environmental Protection Agency
1200 Pennsylvania Avenue, N.W.
Washington, D.C. 20460
Dated JAMES VINCH
Attorney
Water Enforcement Division
Office of Civil Enforcement
Office of Enforcement and Compliance Assurance
United States Environmental Protection Agency
1200 Pennsylvania Avenue,N.W.
Washington, D.C. 20460
U.S. &State of Iowa v. City of Waterloo—Consent Decree—Page 48 of 51
III
THE UNDERSIGNED PARTIES enter into this Consent Decree in the matter of United States
and State of Iowa v. City of Waterloo.
Dated MARK HAGUE
Acting Regional Administrator
U.S. EPA Region 7
11201 Renner Boulevard
Lenexa, KS 66219
Dated CHRISTOPHER MUEHLBERGER
Assistant Regional Counsel
U.S.EPA Region 7
11201 Renner Boulevard
Lenexa, KS 66219
U.S. &State of Iowa v. City of Waterloo—Consent Decree—Page 49 of 51
THE UNDERSIGNED PARTIES enter into this Consent Decree in the matter of United States
and State of Iowa v. City of Waterloo.
FOR THE STATE OF IOWA:
THOMAS J. MILLER
ATTORNEY GENERAL
OF THE STATE OF IOWA
Dated DAVID S. STEWARD
Assistant Attorney General
Environmental Law Division
Iowa Department of Justice
Lucas State Office Building
321 E. 12th Street, Ground Flr.
Des Moines, IA 50319
(515) 281-5351
U.S. &State of Iowa v. City of Waterloo—Consent Decree—Page 50 of 51
THE UNDERSIGNED PARTIES enter into this Consent Decree in the matter of United States
and State of Iowa v. City of Waterloo.
FOR THE CITY OF WATERLOO:
Dated BUCK CLARK
Mayor
City of Waterloo
715 Mulberry Street
Waterloo, IA 50703
(319) 291-4301
U.S. &State of Iowa v. City of Waterloo—Consent Decree—Page 51 of 51
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ATTACHMENT NO. 2
U.S. & State of Iowa v. City of Waterloo
Appendix 3: Criteria for Environmentally Beneficial Project Selection
Criteria for Environmentally Beneficial Project Selection
• The environmental projects described in Paragraph 41(b) of the Consent Decree should
be designed to secure environmental or public health protection and improvements
benefiting the community of Waterloo and/or surrounding areas.
• The environmental projects (including studies needed to identify such projects) will be
designed to advance Iowa's policy to conserve, improve and protect its natural resources
and environment and to prevent, abate and control water, land and air pollution, in order
to enhance the health, safety and welfare of the people of Iowa and their overall social
and economic well-being.
• The following categories of environmental projects advance the objectives of the
preceding paragraphs:
1) Public Health
A public health project provides diagnostic, preventive and/or remedial
components of human health care that are related to the actual or potential
damage to human health caused by the violation(s).
2) Pollution Prevention
A pollution prevention project involves an activity that reduces the generation of
pollution (or reduces conditions that could threaten public health and welfare)
through "source reduction," i.e., any practice that reduces the amount of any
hazardous substance, pollutant or contaminant entering any waste stream or
otherwise being released into the environment, prior to recycling,treatment or
disposal.
3) Pollution Reduction
If a pollutant or waste stream has already been generated or released, a pollution
reduction approach which identifies or employs recycling, treatment, discharge
reduction, containment or disposal techniques—may be appropriate. A pollution
reduction project involves an activity that results in a decrease in the amount
and/or toxicity of any hazardous substance, pollutant or contaminant entering any
waste stream or otherwise being released into the environment by a facility
operated by the City.
4) Environmental Restoration and Protection
An environmental restoration and protection project is one that goes beyond
repairing the damage caused by the violation(s), and enhances the condition of the
ecosystem or immediate geographic area adversely affected or creates additional
infrastructure resilience to protect the urban environment, furthering public health
and safety objectives. These projects may be used to restore or protect natural
environments, such as ecosystems,and man-made environments, such as facilities
and buildings. This category also includes projects that protect the ecosystem
from actual or potential damage resulting from the violation(s), or improve the
overall condition of the ecosystem.
Page 1 of 2
U.S. & State of Iowa v. City of Waterloo
Appendix 3: Criteria for Environmentally Beneficial Project Selection
• Public statements or representations made by the Defendant regarding the environmental
projects shall expressly state that the projects were funded pursuant to a consent decree
resolving a civil action brought by the Iowa Attorney General's Office on behalf of the
State of Iowa to enforce Iowa's environmental laws contained in Iowa Code chapter
455B.
• As of the date of executing this Consent Decree,the City shall demonstrate that it is not
required to perform or develop the environmental projects by any federal, state, or local
law or regulation; is not required to perform or develop the environmental projects by
agreement, grant, or as injunctive relief awarded in the instant action or any other action
in any form; and the environmental projects are not materially related to any remedial or
mitigation measures undertaken by the City to address the violations alleged in this
enforcement action.
Page 2 of 2
City of Waterloo
Waste Management Services Department
3505 Easton Ave, Waterloo, IA 50702
319-291-4553
www.cityofwaterlooiowa.com
Sanitary Sewer Overflow Response Plan
(SSORP):
January 27, 2010
Revision:March 2014
Sanitary Sewer Overflow Response Plan (SSORP)
Table of Contents
Section No.
1. Purpose
2. IDNR Reporting
3. Basement Backups
4. SSO/MManhole Overflows
5. Bypasses
6. Bypass Pumping of a Sanitary Sewer to Storm Sewer/Waterway
7. Posting"Warning Sewage" Signs
8. Containment of SSOs/Manhole Overflows
9. Traffic Control
10. Public and City Website Notification
11. Training
12. Calculating& Visual Estimates of Sewage Volumes for a Basement Backup,
SSO/Manhole Overflow,and Bypass Pumping
13. Definitions
2
Sanitary Sewer Overflow Response Plan (SSORP)
Appendix
A. IAC Environmental Protection [567] Chapter 63.6
B. Procedures of how to enter"SSO& Bypass Public Notification Report Form"
onto city website
C. Manhole Overflow visual pictures to determine Total Gallons
D. Filling-Out: Water Pollution/Flood Control Complaint Information Form by
Office Personnel, Plant Security and Wastewater Operators
E. IDNR Basement Backup, SSO/Manhole Overflow, and Bypass/Pumping Report
Form
F. N. Hackett Lift Station Overflow(Bypass)Controls and Procedures
3
Sanitary Sewer Overflow Response Plan (SSORP)
1. Purpose:
The City of Waterloo Sanitary Sewer Overflow Response Plan(SSORP) is
developed to protect public health,the environment, and property. SSORP is
meant to identify the necessary procedures for notification, response, reporting,
and clean-up of SSOs/Manhole Overflows, Bypasses,and Basement Backups that
may occur within the City of Waterloo's Collection and Treatment System. The
SSORP is designed to dispatch appropriate response personnel to the SSO affect
area(s)or to a notified basement backup location to minimize the volume and land
area that may be affected from a sewage overflow and to minimize property
damage. The source of a SSO shall be stopped or contained as soon as possible.
By documenting and implementing these SSORP practices,the impact of SSOs
and Bypasses on public health and the environment should be reduced.
2. IDNR Reporting:
The IDNR(Iowa Department of Natural Resources)Basement Backup,
SSO/Manhole Overflow,and Bypass/Pumping Report Form is the main tool
that is used for initially documenting a Basement Backup, SSO/Manhole
Overflow, Bypass,or Bypass Pumping Event. Basement Backups cause from a
sanitary sewer main plug/blockage owned/operated by the City of Waterloo, (but
Not building lateral sewer(s)causing plugs/blockages) SSOs/Manhole Overflows,
and Bypasses must be reported not later than twelve(12) hours after the onset or
discovery of the event to the Iowa Department of Natural Resources(IDNR).
All Basement Backups, SSO/Manhole Overflows, Bypasses or Bypass Pumping
events must have an IDNR Basement Backup,SSO/Manhole Overflow,and
Bypass/Pumping Report Form filled out by the responding personnel as a sewer
maintenance worker or other department employee and signed by the Authorized
Representative as an On-Call Foreman, Foreman,or Supervisor.All Report
4
Sanitary Sewer Overflow Response Plan(SSORP)
Forms data will than be entered into the CMOM database for data storage and
retrieval.
Reporting of Basement Backups, SSO//Manhole Overflows, Bypasses or Bypass
Pumping Event
If a Basement Backup, SSO/Manhole Overflow, or Bypass occurs, a Waste
Management Services Department On-Call Foreman, Foreman or Supervisor will
need to contact/notify and report to the Iowa Department of Natural Resources
(IDNR)within Twelve(12)hours after the onset or discovery of the event.
IDNR is contacted at the following phone numbers:
IDNR Manchester Office: 563-927-2640
Manchester Office Hours: 8:00 a.m.—4:30 p.m. Monday—Friday
After Hours/Weekends/Holidays: 515-281-8694
3. Basement Backups:
Phone calls/notifications received for Basement Backups.
If the city sewer main is plugged or surcharged at the basement backup address
and sewage is on the floor of that address, an IDNR Basement Backup,
SSO/Manhole Overflow,and Bypass/Pumping Report Form will need to be
filled out and the sewer maintenance worker will need to phone call/contact and
report to the on-call foreman with the basement backup address and the details of
the basement backup. If No sewage was on the floor,than No IDNR report form
will need to be turned in.The sewer maintenance worker should contact the on-
call foreman as soon as it's known that an IDNR Basement Backup,
SSO/Manhole Overflow, and Bypass/Pumping Report Form will need to be filled
out, unless it is after 10:00 p.m.and no help is needed. If the sewer maintenance
worker did not contact/notify the on-call foreman because it was after 10:00 p.m.
than the sewer maintenance worker will need to contact/notify the on-call
foreman around 7:00 a.m.the next morning on weekends/holidays or report to on-
5
Sanitary Sewer Overflow Response Plan(SSORP)
call foreman at Waste Management Services at 7:00 a.m. during weekdays. But
the sewer maintenance worker MUST contact/notify the on-call foreman before
12 hours from the onset or discovery of the event.
After the on-call foreman receives the information about the basement backup the
on-call foreman will than need to contact and report to the IDNR about the
basement backup. All Basement Backups must be reported not later than 12
hours after the onset or discovery of the event by the On-Call Foreman, Sewer
Maintenance Foreman,or Supervisor to the IDNR. Use the after hours phone
number on weekends, holidays, and evening hours.
If on a Basement Backup call,a sewer manhole is or there has been an overflow,
then the manhole overflow box would need to be checked off on the IDNR
Basement Backup, SSO/Manhole Overflow, and Bypass/Pumping Report Form.
Clean-up and disinfection of the manhole overflow area and temporary"Warning
Sewage"signage would need to be posted.
The sewer maintenance worker will need to fill out the IDNR Basement Backup,
SSO/Manhole Overflow, and Bypass/Pumping Report Form and would need to
give it to the on-call foreman.On weekends or holidays the report will not need to
be given to the on-call foreman at that time, unless requested by the on-call
foreman, but would need to be given to the on-call foreman on the first workday
of the week(as Monday). The on-call foreman will than need to give the report to
a supervisor or if a sewer maintenance worker is not able to give the report to the
on-call foreman than the report may be given directly to a supervisor. A filled out
IDNR Basement Backup, SSO/Manhole Overflow,and Bypass/Pumping Report
Form Must be turned in for each Basement Backup or SSO/Manhole Overflow.
4. SSOs/Manhole Overflows:
Phone calls/notifications received for SSOs/Manhole Overflows.
6
Sanitary Sewer Overflow Response Plan(SSORP)
Whenever a sewer maintenance worker receives a phone call/notification of a
SSO/manhole overflow the on-call foreman will need to be contacted and
notified.The sewer maintenance worker should notify the on-call foreman after
they have checked the manhole overflow site/location for an overflow, have
collected samples, and have hydro flushed and unplugged the sewer main.After
the sewer main has been hydro flushed and unplugged the sewer maintenance
worker would need to fill out an IDNR Basement Backup, SSO/Manhole
Overflow, and Bypass/Pumping Report Form and will need to contact/notify and
report to the on-call foreman about the event. If it is after 10:00 p.m.and no help
is needed,the phone call/notification to the on-call foreman may wait until 7 a.m.
the next morning. If the sewer maintenance worker did not contact the on-call
foreman because it was after 10:00 p.m.than the sewer maintenance worker will
need to contact the on-call foreman around 7:00 a.m.the next morning to report
the SSO/manhole overflow on weekends/holidays or report at Waste Management
Services at 7:00 a.m. during weekdays.
After the on-call foreman or sewer maintenance foreman receives the information
about the SSO/manhole overflow,the on-call foreman or sewer maintenance
foreman will than need to contact/notify and report to the IDNR about the
SSO/manhole overflow. All SSOs/Manhole Overflows must be reported not
later than 12 hours after the onset or discovery of the event by the On-Call
Foreman, Sewer Maintenance Foreman, or Supervisor to the IDNR.
Before hydro flushing an overflowing manhole the sewer maintenance worker
will need to collect two bottles of sample(One with Acid)from the overflow
site/location. Fill-out all information on the sample bottle labels and collect
samples, Fill sample bottles.The samples need to be delivered to the Laboratory
Technician and/or put into the lab refrigerator. If the samples cannot be put in the
lab refrigerator,the sample should be put into the waste hauler refrigerator located
at the first Northeast door of the headworks and then to the first door on the right.
The sewer maintenance worker will need to contact/notify the lab technician to
7
Sanitary Sewer Overflow Response Plan (SSORP)
report the collection of the samples and where the sample bottles are located (as
lab or waste hauler refrigerator)right after 7:00 a.m. except on Sundays. Keep
two sample bottles in the flusher truck and the sewer maintenance worker that
uses the sample bottles needs to replace those sample bottles.
The sewer maintenance worker will need to have the overflow/SSO area(s)
(streets, lawns, sidewalks, and public areas) isolated from the public by
barricading/coning/safety tapping off the affected area(s). The affected area(s)
will need to have temporary"Warning Sewage"signage posted around the
affected area(s)and at entry point where the overflow/SSO enters the stream,
creek, or river. The affected area(s) will need to be cleaned up as:standing water
will need to be vacuumed up and rag, grease, and trash cleaned up. In the Action
Taken/Resolution section of the IDNR report form write the clean-up action and
the disinfection that was performed.The overflow/SSO affected area(s)will need
to be disinfected with chlorine bleach or lime;the use of chlorine in the streets is
preferred. Use a two-gallon lawn sprayer with chlorine bleach to spray overflow
area. Do Not flush/hose the sewage overflow area in a storm drain.
All private property that has a SSO/Overflow on their property must be contacted
by phone or in person that a sewage overflow occurred and where the overflow is
located on their property. "Warning Sewage"signage and barricade tape shall be
posted around the sewage overflow affected area.
The sewer maintenance worker will need to fill out an IDNR Basement Backup,
SSO/Manhole Overflow,and Bypass/Pumping Report Form.
Information that is included on the Report Form:
• The reason for the bypass (overflow), including the amount(volume)and
duration of any rainfall event that may have contributed to the bypass;
(Supervision will fill in the rainfall amount)
• The date and time of onset or discovery of the bypass;
8
Sanitary Sewer Overflow Response Plan(SSORP)
• The duration of the bypass;
• An estimate of the amount of untreated or partially treated sewage or
wastewater that was discharged; (give a description of the overflow)
• The location of the bypass; and
• The name of any body of surface water that was affected by the bypass
(Appendix A: IAC Environmental Protection [567] Chapter 63.6(3)(d)).
Fill-out the IDNR Basement Backup, SSO/Manhole Overflow, and
Bypass/Pumping Report Form as much as possible and deliver to on-call foreman,
foreman,or supervisor by 7:00 a.m.on weekdays, if Basement Backup or SSO
call/notification is completed after 3:00 p.m. All Basement Backups,
SSOs/Manhole Overflows, and Bypass/Pumping between the hours of 3:00 p.m.
and 10:00 p.m.Must be reported to the IDNR after the event has happened by the
on-call foreman. If the Basement Backup or Manhole Overflow was during the
weekday working hours of 7 a.m. to 3 p.m. and the Basement Backup or Manhole
Overflow has been completed, with the Report Form filled out, by 3:00 p.m.than
the IDNR Report Form maybe delivered to a supervisor and reported to IDNR by
a supervisor. All Basement Backups,SSOs/Manhole Overflows,and Bypasses
must be reported not later than 12 hours after the onset or discovery of the
event by the On-Call Foreman, Sewer Maintenance Foreman,or Supervisor to the
IDNR.
Overflow Volumes Recovered in gallons.
Any volumes of SSO that was recovered or sewage volumes hauled from one part
of the collection system to another, stopping or reducing an overflow, by Waste
Management Services vacuum truck or by a private tank hauler company. Loads
will need to be counted and volumes/gallons calculated.
9
Sanitary Sewer Overflow Response Plan(SSORP)
5. Bypasses:
When a Flow Equalization(FEQ)Basin Bypass occurs an IDNR Basement
Backup, SSO/Manhole Overflow, and Bypass/Pumping Report Form will need to
be filled out by the on-call foreman or operations foreman.
The On-Call Foreman or Operations Foreman will need to be contacted/phoned
and be notified of an FEQ Basin Bypass by the wastewater operator or plant
security at the start of the Bypass.A FEQ Basin Bypass must be reported not
later than 12 hours after the onset or discovery of the event by the On-Call
Foreman, Operations Foreman, or Supervisor to the IDNR.
A sample will need to be collected for each day that the FEQ Basin is bypassing
by a Laboratory Technician or Wastewater Operator. If a Laboratory Technician
or Wastewater Operator can't be contacted the sample may be collected by the
on-call foreman.
A "Warning Sewage"sign will need to be posted at the river/waterway location of
the sewage entry point, when river/waterway water levels permit it to be posted.
The FEQ Basin Bypass flow meter will need to be turned ON when the West(# 2)
FEQ Basin is around the seven(7)ft. level and level raising and turned OFF
around the seven(7) ft. level and level falling by a wastewater operator,
operations foreman,or on-call foreman.
Another location where a bypass may happen is N.Hackett lift station.The first
responding employee, at the bypass location, as plant maintenance mechanic,
instrumentation control technician, sewer maintenance worker, foreman or any
other department employee will need to report/contact and notify the on-call
foreman of the bypass.The first responding employee will need to fill-out an
IDNR Basement Backup, SSO/Manhole Overflow, and Bypass/Pumping Report
Form and deliver report form to the on-call foreman.
I0
Sanitary Sewer Overflow Response Plan(SSORP)
6. Bypass Pumping of a Sanitary Sewer to Storm Sewer/Waterway:
Complaint phone calls/notifications received by residents asking for a portable
pump, because of high rainfall amounts or sewer surcharge.
• Sewer maintenance foreman,on-call foreman, or a supervisor will
determined if a portable pump is needed and if a portable pump will be
set-up at the complaint location.
Fill-out both sides of sheet, "Sewer Overflow Sheets" on one side of sheet and
"IDNR Basement Backup, SSO/Manhole Overflow, and Bypass/Pumping Report
Form"on other side of sheet, when running a portable pump for bypassing. Give
sheet/form to on-call foreman or a shift foreman (a sewer maintenance worker)
when bypass pumping continues on for many shifts or days,to complete
sheet/form when pumping is complete.Bypass Pumping must be reported not
later than 12 hours after the onset or discovery of the event by the On-Call
Foreman, Foreman,or Supervisor to the IDNR.
When changing portable pump Pump Speed as minimum, medium &high,write
on sheet/form,under Pump Speed, the date&time of the changed pump speed
and the speed of pump.
Samples will need to be collected when a portable pump is started. Collect two
bottles of sample(One with Acid) from the portable pump location. Fill-out all
information on the sample bottle labels and collect samples, Fill sample bottles.
The samples need to be taken/delivered to the Laboratory Technician and/or
put/placed into the lab refrigerator. If the samples cannot be put in the lab
refrigerator,the samples should be taken to the waste hauler refrigerator located at
the first Northeast door of the headwork's and then to the first door on the right.
The sewer maintenance worker will need to contact/notify the lab technician to
report the collection of the samples and where the sample bottles are(as lab or
waste hauler refrigerator)right after 7:00 a.m.except on Sundays.
II
Sanitary Sewer Overflow Response Plan (SSORP)
Collect sample(s)for E. coli if a portable pump is running during the weekday
regular working hours,as E. coli sample(s)have to be turned in to Test America
within six(6)hours of collection. On-call foreman or sewer maintenance foreman
will need to notify a lab technician if any portable pump(s)are running during the
workday, 7:00 a.m.to 3:00 p.m. hours, so an E. coli sample(s)can be collected.
Four(4)& Six(6) inch portable pump hour meter hours must be logged on
"Sewer Overflow Sheets" or portable pump form. If an hour meter reader is not
working on a portable pump, notify the sewer maintenance foreman with the
pump number.
7. Posting"Warning Sewage" Signs:
All SSOs/Manhole Overflows, Bypasses, and Bypass pumping from a portable
pump should have a"Warning Sewage"sign(s) posted at overflow or bypass
pumping location and at the entry point of a waterway,creek,stream,or river.
Sewage overflows or sewage bypasses pumping to a creek or waterway that flow
throw or next to a public area, as a park or school,should have a sign(s)posted at
thoughts locations.
Signs will be marked with a date number and a three-digit permanent sign
number.The numbers all together will be called the Reference Sign(s)Number.
The reference sign number will be seen as: 4-15-14 001 or 5/03/14 015.All
"Warning Sewage"signs posted to a manhole overflow or bypass pumping
location need to have the reference sign number(s)entered on the IDNR
Basement Backup, SSO/Manhole Overflow, and Bypass/Pumping Report Form.
8. Containment of SSOs/Manhole Overflows:
The sewer maintenance worker or responding employee responding to the SSO
incident shall first initiate measures to stop the overflow by hydro flushing the
12
Sanitary Sewer Overflow Response Plan(SSORP)
sewer to unplug the main or by restarting a lift station causing the SSO, if the
these measures don't stop the overflow than the next step is containment of the
overflowing sewage and to recover as much of the overflow/spilled sewage as
possible.
Determine the immediate destination of the overflow(e.g. storm sewer, body of
water or creek, or on the ground).
Identify and request, if necessary,assistance or additional resources(materials
and equipment)to contain or isolate the overflow.
Steps to contain the overflow(e.g. block storm sewer, recover sewage with a
vacuum truck, divert into a downstream manhole, block storm sewer down stream
to contain sewage and recover may be performed in dry weather conditions).
9. Traffic Control:
Traffic control may be needed to protect the public or sewer maintenance staff.
Typically, immediate traffic control is needed if there is a street collapse or
significant depression in the pavement that is related to the sewer, or if the
overflow causes flooding of the street.Traffic control may also be needed to
prevent wastewater from being further disbursed and to protect the sewer
maintenance worker while containing the overflow and removing the blockage.
If necessary, use other departments including Police Dept.or Public Works Dept.
to ensure proper traffic control.
• Waterloo Police Department: (319)291-4340 for Non-emergency No.
• Public Works Department: (319)291-4445
10. Public and City Website Notification:
On-call foreman will need to enter a SSO(s)or Bypass(es) information into the
"SSO & Bypass Public Notification Report Form" and have the filled-out form
sent to the city website location.The"SSO & Bypass Public Notification
13
Sanitary Sewer Overflow Response Plan (SSORP)
Report Form" must be posted on city website not later than 12 hours after the
onset or discovery of the event.
An email notification will be sent to the Waterloo/Cedar Falls Courier and Black
Hawk County Health Department when a"SSO& Bypass Public Notification
Report Form" is sent to the city website.
Appendix B is the procedures of how to enter"SSO& Bypass Public Notification
Report Form" into city website by the Foreman's and Supervisor's.
11. Training:
Training should be preformed annually in March on this SSORP.
Copy of the SSORP will be available by request and posted at Sewer Maintenance
bulletin board.
12. Calculating& Visual Estimates of Sewage Volumes for a Basement Backup,
SSO/Manhole Overflow,and Bypass Pumping:
Calculating for a Basement Backup
Volume of a Rectangle=Length(ft)x Width(ft)x Depth(ft)x 7.48 gals/cu.ft.
=Gallons/cu. ft.
Volume of a Cylinder=0.785 x Diameter(ft)2(sq)x Depth(ft)x 7.48 gals/cu. ft.
=Gallons/cu. ft.
Calculating for a SSO/Manhole Overflow
Use Manhole Overflow visual pictures in Appendix C to determine Total Gallons
Total Volume,gallons= Estimated Overflow gpm (Picture)x Time(minutes)
Calculating for Bypass Pumping
Pumping gallons for a Four(4) inch pump.
• Pump Speed: Minimum =200 gpm, Medium =300 gpm, &
14
Sanitary Sewer Overflow Response Plan (SSORP)
High=400 gpm
Pumping gallons for a Six(6) inch pump.
• Pump Speed: Minimum =425 gpm, Medium=760 gpm, &
High=900 gpm
Total Pumping, Gallons=Pumping gpm x Time(minutes)
13. Definitions:
Bypass
The intentional diversion of wastestreams from any portion of a treatment(or
pretreatment) facility.(EPA)
Bypass
The diversion of waste streams from any portion of a treatment facility or collection
system.A bypass does not include internal operational waste stream diversions that are
part of the design of the treatment facility, maintenance diversions where redundancy is
provided, diversions of wastewater from one point in a collection system to another point
in a collection system, or wastewater backups into buildings that are caused in the
building lateral or private sewer line. (567-IA Chapter 60.2(455B) Definitions)
Bypass Pumping
An arrangement of pipes and valves whereby the flow may be passed around a hydraulic
structure or appurtenance. Also, a temporary setup to route flows around a part of a sewer
system.
Gallons Per Minute
Gallons Per Minute=gpm
Overflow
(1)The excess water that flows over the ordinary limits of a sewer, manhole,or
containment structure. (2)An outlet, pipe,or receptacle for the excess water.
Sanitary Sewer
A sewer intended to carry only sanitary or sanitary and industrial wastewaters from
residences, commercial buildings, industrial parks, and institutions.
Sanitary Sewer Overflows(SSO)
Untreated or partially treated sewage overflows from a sanitary sewer collection system.
(EPA)
Sewer Main
A sewer pipe to which building lateral/sewer are connected.
15
Sanitary Sewer Overflow Response Plan (SSORP)
Surcharge
When the sewer flow exceeds the hydraulic carrying capacity of the sewer line.
Waterway
1. Any body of water,other than the open sea,which is or can be used by, boats as a
means of travel.2.Any natural or artificial channel or depression in the surface of the
earth,which provides a course for water flowing either continuously or intermittently.
16
Sanitary Sewer Overflow Response Plan (SSORP)
Appendix A
IAC Environmental Protection [567] Chapter 63.6
567 IAC
63.6(3)Notification of unanticipated bypass or upset and public notices.
In the event that a bypass or upset occurs without prior notice having been provided
pursuant to 63.6(2) or as a result of mechanical failure or acts beyond the control of the
owner or operator, the owner or operator of the treatment facility or collection system
shall notify the department by telephone as soon as possible but not later than 12 hours
after the onset or discovery.
a. Notification shall be made by contacting the appropriate field office during normal
business hours (8 a.m.to 4:30 p.m.) or by calling the department at (515)281-8694 after
normal business hours.
b. Notification shall include information on as many items listed in subparagraphs
63.6(3)"d"(l)through (6)as available information will allow.
c. When the department has been notified of an unanticipated bypass, the department
shall determine if a public notice is necessary. If the department determines that public
notification is necessary, the owner or operator of the treatment facility or the collection
system shall prepare a public notice.
d. Bypasses shall be reported with the monthly operation report, as a separate attachment,
that includes:
(1) The reason for the bypass, including the amount and duration of any rainfall event
that may have contributed to the bypass;
(2)The date and time of onset or discovery of the bypass;
(3)The duration of the bypass;
(4) An estimate of the amount of untreated or partially treated sewage or wastewater that
was discharged;
(5) The location of the bypass;and
(6)The name of any body of surface water that was affected by the bypass.
63.6(4)Monitoring, disinfection, and cleanup.
The owner or operator of the treatment facility or collection system shall perform any
additional monitoring, sampling, or analysis of the bypass or upset requested by the
regional field office of the department and shall comply with the instructions of the
department intended to minimize the effect of a bypass or upset on the receiving water of
the state.The following requirements for disinfection and cleanup apply to all bypasses:
a. The department may require temporary disinfection depending on the volume and
duration of the bypass, the classification of the stream affected by the bypass, and the
time of year during which the bypass occurs;and
17
Sanitary Sewer Overflow Response Plan(SSORP)
Appendix A
b. The department may require cleanup of any debris and waste materials deposited in the
area affected by the bypass. In conjunction with the cleanup, the department may require
lime application to the ground surface or disinfection of the area with chlorine solution.
63.6(5) Reporting of subsequent findings and additional information requested by the
department.
All subsequent findings and laboratory results concerning a bypass shall be submitted in
writing to the appropriate regional field office of the department as soon as they become
available. Any additional information requested by the department concerning the steps
taken to minimize the effects of a bypass shall be submitted within 30 days of the request.
18
Sanitary Sewer Overflow Response Plan(SSORP)
Appendix B
Procedures of how to enter"SSO& Bypass Public Notification Report Form- into city
website
Uploading a Completed SSO Bypass Public Notification Report Form
I After completing the form go to file
2 Chck on Save As
3 Chet on Desktop
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19
Sanitary Sewer Overflow Response Plan (SSORP)
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Sanitary Sewer Overflow Response Plan (SSORP)
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7 0;en up Croogde Dore on the enteric
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21
Sanitary Sewer Overflow Response Plan(SSORP)
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Sanitary Sewer Overflow Response Plan(SSORP)
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23
Sanitary Sewer Overflow Response Plan (SSORP)
IOU\O'
City of Waterloo, IA
Public Notification
Sanitary Sewer Overflow (SSO) &Bypass
NPDES Permit#:0790001
Report Submitted/Posted Date&Time:
Date Time 7,71AM 4.t PM Q
Address/Location ofSSO/Bypass:
Start/Discovery Date&Time El
SSO/Bypass
Date'Y Time E ;ydAM ElPMEl
Stop/Completion Date&Time of SSO/Bypass
Date. Time ,, AM PM n
OR I]Ongoing SSO/Bypass
Reason/Cause of SSO/Bypass Event:(Check all that apply)
Q Rain/Snow Melt Q FOG/Fats,Oils& QLift Station Power
El Equipment Failure Grease-Blockage Failure
El Vandalism ®Roots-Blockage ta Debris/Rags-
Other-explain (]Structural Damage Blockage
below
Provide a narrative description to further explain why the SSO or Bypass occurred:
Duration of SSO/Bypass:
Hours 77(Minutes ". y OR Ongoing SSO/Bypass
SSO/Bypass Discharged From:;" .,
Did Sewage get to a Body of Water or Storm Sewer.El Yes or 0 No
SSO/Bypass Discharged To(Affected Water Body Name(s)):
Ground Surface(No release to Storm Sewer or Surface Water)
0 Street(No release to Storm Sewer or Surface Water)
0 Street to Storm Sewer:�e
El Storm Sewer.
0 Surface Water Direct Discharge:1,
24
Sanitary Sewer Overflow Response Plan(SSORP)
Q Ditch: , ,m
Other,Describe: " _44,k3
Estimated Volume of SSO/Bypass Discharged(Gallons):
El Estimated Gallons:* :
[l No Estimated Gallons
Action Taken/Resolution: *,
'Warning Sewage"Sign(s)Posting:
Q Yes,"Warning Sewage" Sign(s) are posted
El No,'Warning Sewage"Sign(s)are posted
Reference"Warning Sewage" Sign(s) Number
Barricade(s)/Safety Tape Placement:
Barricade(s)/Safety Tape are set up/in place
No,Barricade(s)/Safety Tape are set up/in place
Were Samples Collected: []Yes or Li No
Q Iowa DNR have been notified
0 Email Notification to Waterloo/Cedar Falls Courier and Black Hawk County
Health Department
Comments/Other Actions Taken
For more information concerning this incident,please contact:
Contact:Larry Smith,Superintendent
City of Waterloo,Waste Management Services Department
319-291-4553
25
Sanitary Sewer Overflow Response Plan(SSORP)
Public Notification email:
Public Notice:
The City of Waterloo, Iowa Waste Management Services Department would like to notify Waterloo-
Cedar Falls Courier and Black Hawk County Health Department that a new"SSO&Bypass Public
Notification Report Form" has been placed on the City of Waterloo's website. If there are any questions
regarding this email, please contact Waste Management Services at 319-291-4553.
Thank you,
Email notification to:
Waterloo-Cedar Falls Courier Newsroom if: 1-800-798-1702
news roo m(al wcfcou rie r.com
Tim Jamison Waterloo-Cedar Falls Courier City Reporter 319-291-1577
tim.iamison@wcfcourier.com
Black Hawk County Health Department Jon McNamee#:319-291-2413
publichealth@co.black-hawk.ia.us
jonmcna meets co.black-hawk.ia.us
Note:Send email to all four email addresses.
Google Drive:
User name:waterloowastemanagement
Password:
26
Sanitary Sewer Overflow Response Plan (SSORP)
Appendix C
Manhole Overflow visual pictures to determine Total Gallons
Appendix C
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27
Sanitary Sewer Overflow Response Plan(SSORP)
Appendix D
Filling Out: Water Pollution/Flood Control Complaint Information Form
For Basement Backups, SSOs/Manhole Overflows and FEO Basin Bypasses
By Office Personnel,Plant Security and Wastewater Operators
• When receiving phone calls for a Basement Backup or SSO/Manhole Overflow
fill out a Water Pollution/Flood Control Complaint Information Form as
completely as possible.
• When receiving a phone call for a Basement Backup, supervision would like the
person receiving the phone call to ask:
o To what extent is the Basement Backup?
As: How large of an area does the water cover on the floor around your
drain. Example: 5 foot by 5 foot by %2 inch deep area?Or,a 3 feet
circle/diameter around the drain that is %a inch deep?
• After receiving the complaint phone call contact the on-call sewer maintenance
worker with the complaint call or contact the on-call foreman, if the on-call sewer
maintenance worker can't be contacted.
• If,the received phone call is at night,ask the resident/or person calling if they
could turn on their front door light,so the sewer maintenance worker may be able
to see the address number.
• The On-Call Foreman will need to be contacted/called and notified of a Flow
Equalization (FEQ)Basin Bypass by the wastewater operator or plant security,
when the start of the bypass occurs. A FEQ Basin Bypass must be reported not
later than 12 hours after the onset or discovery of the event by the On-Call
Foreman, Operations Foreman, or Supervisor to the IDNR.
Thank You for Your Cooperation with these procedures.
28
Sanitary Sewer Overflow Response Plan(SSORP)
Appendix E
IDNR Basement Backup, SSO/Manhole Overflow, and Bypass/Pumping Report Form
WATERLOO WATER POLLUTION FLOOD CONTROL
IDNR BASEMENT BACKUP,SSO/MLANHOLE OVERFLOW,AND BYPASSPUMPING REPORT FORM
CALL IN(DISCOVERY) Use Foam TX en
DATE TIME BuementBa kup&Main Plugged,
NAME. Basement Backup&Surcharge,
Bypass-EQ Basin,Bypass-Pumping Other
ADDRESS: &SSO Manhole Overflow
PHONE e- CONTACT IDNR.
909 West Main Suite as
COMPLAINT PROBLEhi Manchester,IA 52057
Phone d:(563)927-2640(8 am to 4 30 pm)
After Hours Phone n:(515)281-8694
BASEMENT ACCESS:Allowed Access( )Denied Access( ) Fax ii:(563)927-2075
BASEMENT BACKUP( );MAIN PLUGGED( )YES( )NO; Admiaistratis'e Use:Planned Action to
BYPASS.EQ Basin();BYPASS-Pumping Other( SURCHARGE()YES( )NO; Recent Future SSO/Bypass:
SSO'MANHOLE OVERFLOW( ).'Check all that apply.
REPORTING PERSON: WAS A SAMPLE COLLECTED'
SITE ARRIVAL TIME. ( )YES or( )NO
COMPLETION STOP DURATION OF SSO BYPASS' Pa• c NoOScaton Postings&Email
DATE&TIME City Webstte. �WCF Courier.
WAS IT RAINING:( )YES or( )NO ESTIMATED VOLUME OF SEWAGE IDNR Person Reported To Contacted
RAINFALL AMOUNT. DISCHARGED:
ACTION TAKEN/RESOLUTION. Datellme Reported to IDNA
REASON OF BACKUP,SSO or BYPASS:Rain:Sums Melt( );FOG Grease( );LS Authorized RepresemativeName(Print):
Power Failure( ),Equipment Failure( ),Roots( );Debris:Rags( ):Vandalism( );
Structural Damage( );Other _ ( ).'Check all that apply.
DID THE SEWAGE GET TO A BODY OF WATER OR STORM DRAIN'?( )YES Signature of Authorized Represent Iwe
or( )NO;AFFECTED WATER BODY NAME(S):
POSTED WARNING SEWAGE�I1C,•y7;()YES(INO ON-CALL FOREMAN
8efereneeSign(s)s:.
Instructions:Report to IDNR no later than 12 hours after the onset or discovery of the event If there is a SSO/Bypasr.Barricade
Safety Tape affected area,clean up sewage.disinfect contaminated area with cblorinebleacborlime&Post Warning Sewage sign(s).
Notes Must give"Estimated Volume of Sewage Discharged"and nun in formto On-Call Foreman or Supervisor.4®e.es.n r to
29
Sanitary Sewer Overflow Response Plan(SSORP)
SEWER OVERFLOW SHEETS
Collect Two Sample Bottles*
PUMP NUMBER:
PUMP START DATE/TIME:
PUMP STOP DATE/TIME:
LOCATION:
PUMP SIZE USED:
PUMP SPEED (minimum, medium or high)
PUMP START/STOP HOURS:
COLLECTOR:
PELItER SAMPLES AX4P iv LAB.
SEEP SAMPLES COOL OR REFRIGERATED
EACBSAMPLE mar BEACCOMPL D BITERS SBEET.
30
Sanitary Sewer Overflow Response Plan (SSORP)
May 28,2013
Revision:Sept 22,2014
Did sewage get to a Body of Water or Storm Drain
Affected Water Body Namels):
• 2415 or 2566 Saratoga Dr: storm drain to Dry Run Creek to Cedar River
• 1900 Block Downing Ave: storm drain to Black Hawk Creek to Cedar River
(Between Westland Ave&Scott Ave)
• Upland Ave&Muncy Ave: storm drain to Black Hawk Creek to Cedar River
• 242 N.Hackett Rd.Lift Station: Unnamed Creek to Cedar River
(Castle Hill Watershed)
• Letsch Rd&Pleasant Valley Dr: ditch in Pleasant Valley Watershed to Cedar River
• West 8t St&Locke Ave: storm drain to Dry Run Creek to Cedar River
• Roland Ave&Locke Ave: storm drain to Dry Run Creek to Cedar River
• Sager Ave&kinbud Ln: storm drain to Black Hawk Creek to Cedar River
• Hall Ave&Midland St storm drain to Cedar River
• 800 Block Jane St ditch to Sunnyslde Creek to Black Hawk Creek to Cedar River
31
Sanitary Sewer Overflow Response Plan(SSORP)
Appendix F
N. Hackett Lift Station Overflow(Bypass)Controls and Procedures
Holding Tank level controls:
1. Lower float ball signals the dialer to activate the call list.
• This float ball level is located 5 ft. below the bottom of the overflow pipes,
from lower float ball alarm to upper float ball overflow an estimated time
of one and one half hour until overflow.
2. Upper float ball signals the Bypass hour meter to run when the Holding Tank
pump runs.
• This float ball level is located evenly with the bottom of the overflow
pipes.
• This float ball does not activate an alarm, but only the Bypass hour meter
and the hour meter ON indicator light above the hour meter.
3. If a Holding Tank Overflow occurs, the total hours on the Bypass hour meter for
that overflow period will need to be recorded in a filled out SSO Report/IDNR
Basement Backup and Manhole Overflow Report Form.
• During All Overflows there must be one set of two sample bottles(one
sample bottle has Acid in it)collected, filled, and delivered to the lab or
placed into the lab refrigerator or placed into waste hauler refrigerator
during that 24-hour period (a 24-hour period is Saturday at 7 a.m.to
Sunday at 7 a.m.).
4. If there is a High Wetwell Alarm the Hold Tank Pump has been running.
5. All employees who see an Overflow must turn in the Overflow to the On-Call
Foreman or Supervisor.
6. Holding Tank size:
• 18.5'wide x 62' long x I4.33'depth = 16,436.5 cu. ft.
• 16,436.5 cu. ft. x 7.48 gals/cu. ft.= 122,945 gals total
• 122,945 gals/14.33 ft.depth=8,580 gals/ft.
7. Estimated Holding Tank Pump Gallons per Minute=890 gpm
32
U.S.& State of Iowa v. City of Waterloo
Appendix 5: Long Term Flow and Rainfall Monitoring
Long-Term Flow and Rainfall Monitoring Program
1. The Long-Term Flow and Rainfall Monitoring Program is intended to provide the City
with the ability to assess overall Sanitary Sewer System performance and track wastewater flow
patterns across the City. The data collected during this Program are expected to:
a. assist in determining the potential types of Infiltration/Inflow sources in the Sanitary
Sewer System,
b. provide a basis for identifying specific geographic areas for focused
Infiltration/Inflow field investigations,
c. provide wastewater flow and rainfall data for any ongoing efforts to calibrate and
apply the hydraulic model,
d. help identify capacity-restricted existing Sanitary Sewer System components,
e. help evaluate the effectiveness of Sanitary Sewer System remedial measures
constructed to reduce Infiltration/Inflow and to resolve hydraulic constraints, and
f. help identify new capacity and condition issues as they develop.
2. The Long-Term Flow and Rainfall Monitoring Program shall be performed as part of the
City's CMOM Program. At the conclusion of the Capacity Assessment and as included in the
Sanitary Sewer Master Plan, the City shall identify locations where long-term flow and rainfall
monitoring will be performed.
3. Flow monitoring locations under the Long-Term Flow and Rainfall Monitoring Program
may include a combination of permanently-installed pump station flow meters and permanently-
installed gravity sewer flow meters as determined by the City using sound engineering judgment.
Temporary flow meters may be also used to supplement permanent meter data in specific
drainage areas to assist in focusing the monitoring data collected. The number of permanent
flow metering locations should be based upon typical rainfall distribution patterns across the
City, coordinated with the City's Sanitary Sewer System analysis and operations objectives.
Pump station flow meters should be of a direct-reading, continuous-recording type, capable of
taking totalized readings based upon set time periods and at uniform incremental time intervals
within those set periods consistent with the input data requirements of the City's Sanitary Sewer
System hydraulic model. Gravity sewer flow meters should be continuous-recording, velocity-
depth type meters, unless impracticable, capable of taking totalized readings based upon set time
Page 1 of 2
U.S. & State of Iowa v. City of Waterloo
Appendix 5: Long Term Flow and Rainfall Monitoring
periods and at uniform incremental time intervals within those set periods consistent with the
input data requirements of the City's Sanitary Sewer System hydraulic model.
4. The number and locations of permanent rainfall monitoring locations under the Long-
Term Flow and Rainfall Monitoring Program should be based on typical rainfall distributions
across the City. As much as is practical, rain gauge locations should be coordinated with the
permanent flow monitoring locations. Rain gauges should be of a continuous-recording type
capable of taking totalized readings based upon set time periods and at uniform incremental time
intervals within those set periods consistent with the input data requirements of the City's
Sanitary Sewer System hydraulic model. When temporary flow meters are being utilized to
supplement the permanent flow meters to gather more detailed flow data in specific drainage
areas, the City should evaluate if additional temporary continuous-recording rain gauges also
should be deployed.
5. The City shall maintain records of the flow metering and rainfall monitoring collected for
a running period of not less than 5-years to provide a basis for determining and demonstrating
wastewater flow patterns and trends in the Sanitary Sewer System and establishing the effects of
rainfall on those patterns and trends.
Page 2 of 2
U.S.& State of Iowa v. City of Waterloo
Appendix 6: Sanitary Sewer System Condition Assessment
Sanitary Sewer System Condition Assessment
The City shall conduct a targeted inspection and assessment of the condition of its Gravity
Sewer Mains, Manholes,Pumping Stations, and Force Mains within the Sewer System.The
targeted inspection and assessment activities are designed to identify structural defects and
sources of Inflow and Infiltration(I/I)in the Sewer System that have caused or significantly
contributed to previous SSOs, Building Backups and Prohibited Bypasses; and/or are likely to
cause or significantly contribute to future SSOs, Building Backups and Prohibited Bypasses.
The Condition Assessment shall evaluate the condition of the Sewer System through a series
of investigative steps, including the following specific activities and taking into consideration
the process outlined in the attached Condition Assessment Process Flowchart.
1. The Condition Assessment is intended to:
a. Identify stormwater cross connections and unauthorized direct
connections in the Sewer System;
b. Identify conditions in the Sewer System that contribute to SSOs,
Building Backups and Prohibited Bypasses,such as:
i. physical and/or structural conditions of Gravity Sewer Lines and Manholes
rated in accordance with the City's condition assessment rating program;
ii. I/1 sources in the Gravity Sewer Lines and Manholes rated in accordance
with the City's condition assessment rating program;
iii. physical conditions and design constraints of Force Mains; and
iv. physical conditions and design constraints of Pumping Stations,
including failure of individual pumps,lack of redundant pumps, and
lack of alternative power sources.
c. Identify Force Main conditions based upon City maintenance records. Perform
a visible inspection and function tests of accessible Force Main appurtenances,
such as,but not limited to:control valves,surge protection valves,air relief valve
and vacuum breaker valves.Visually inspect the ground surface over the
entire length of each Force Main for leakage or other indications of force
main deterioration;
Page 1 of 9
U.S.& State of Iowa v. City of Waterloo
Appendix 6: Sanitary Sewer System Condition Assessment
d. Include a force main inventory listing that includes the force mains in the Sewer
System indicating pipe material(s),age or installation date,diameter, length,
special corrosion protection measures, if any,and typical flow rates and
operating pressures.
2. Data Review and Management. In preparing the Condition Assessment,the City shall
review known data concerning SSOs, Building Backups and Prohibited Bypasses, and
Sewer System attributes,and identify additional Sewer System attribute data needed.
3. Investigative Activities.As part of its Condition Assessment,the City shall perform
investigative activities in Service Areas or portions of Service Areas determined to
have excessive wet-weather flow suspected through best engineering judgment to
significantly contribute to SSOs, Building Backups and Prohibited Bypasses,and
increased flow at the WWTP that may cause the facility to exceed permit limitations.
The investigative activities shall identify physical conditions and/or design
constraints of the Sanitary Sewer System(including Force Mains and Pump Stations)
that cause or significantly contribute to SSOs, Building Backups and Prohibited
Bypasses, or increased flow at the WWTP that may cause the facility to exceed
permit limitations.
a. The investigative activities shall be sufficient to allow characterizations of Sewer
System structural conditions and other Sewer System limitations that contribute to
SSOs,Building Backups and Prohibited Bypasses in the Service Areas.The
investigative activities shall include CCTV inspection of non-plastic Gravity Sewer
Lines, visual inspection of manholes, and where appropriate the following additional
investigations as necessary:
i. Smoke testing;
ii. Visual inspections, including CCTV as necessary,of other Gravity Sewer Lines
suspected by the City to have severe structural defects that have caused previous
SSOs,Building Backups and Prohibited Bypasses or are likely to cause future
SSOs,Building Backups and Prohibited Bypasses;
iii. Dye testing of storm sewers with concurrent CCTV of nearby sanitary
sewers; and,
Page 2 of 9
U.S.& State of Iowa v. City of Waterloo
Appendix 6: Sanitary Sewer System Condition Assessment
iv. External building inspections.
b. The City shall inspect its Manholes and assess Gravity Sewer Mains eight(8) inches
or greater in diameter that have not been slip-lined, CIPP-lined, replaced, or pipe-
burst in accordance with the schedule below. Gravity Sewer Mains and Manholes
that have been inspected since 2012 shall be credited towards the City's
compliance obligations. The City may use CCTV, sonar,360-degree video, laser
imagining, or other methods normally utilized by other sewer management agencies
to perform the Gravity Sewer Main inspections.
i. Manholes and Gravity Sewer Mains within Service Areas 15 and 16 shall
be assessed by September 30, 2016 and the results reported, in accordance
with Paragraph 4 of this Appendix, by December 31, 2016.
ii. Manholes and Gravity Sewer Mains within those portions of Service Areas
10, 11, 12, 13 and 19 determined by the City using best engineering
judgment to have excessive wet-weather flow, shall be assessed and results
reported, in accordance with Paragraph 4 of this Appendix, as part of the
Master Plan due December 31, 2017.
iii.Manholes and Gravity Sewer Mains not assessed pursuant to paragraph
3.b.i or 3.b.ii above shall be assessed in accordance with the CMOM
program and reported annually in accordance with Paragraphs 43 and 44
of the Consent Decree.
c. The City shall inspect all of its Pumping Stations, and Force Mains in accordance
with the schedule below, using appropriate methods. Any Force Main inspections
conducted by the City since January 1, 2012, shall count towards the City's
compliance with this paragraph.
i. Pumping Stations, and Force Mains located within Service Areas 15 and
16 shall be assessed by September 30, 2016 and the results reported, in
accordance with Paragraph 4 of this Appendix, by December 31, 2016.
ii. Pumping Stations, and Force Mains located within those portions of
Service Areas 10, 11, 12, 13 and 19 determined by the City using best
engineering judgment to have excessive wet-weather flow, shall be
assessed and results reported, in accordance with Paragraph 4 of this
Page 3 of 9
U.S.& State of Iowa v. City of Waterloo
Appendix 6: Sanitary Sewer System Condition Assessment
Appendix, as part of the Master Plan due December 31, 2017.
iii.Pumping Stations, and Force Mains not assessed pursuant to paragraph
3.c.i or 3.c.ii above shall be assessed in accordance with the CMOM
program and reported annually in accordance with Paragraphs 43 and 44
of the Consent Decree.
4. The City's reports on the status of the Capacity Assessment activities,pursuant to Paragraphs
3.b.i,3.b.ii,3.c.i,and 3.c.ii of this Appendix,shall provide all information required under the
Condition Assessment Report Template as applicable to the specific assessment activities
performed by the City. The Condition Assessment reports shall be submitted to EPA in
accordance with Section VII of the Consent Decree(Review and Approval Procedures).
Page 4 of 9
U.S.& State of Iowa v.City of Waterloo
Appendix 6: Sanitary Sewer System Condition Assessment
Sewer& Manhole Condition
Assessment Process Flowchart
1/1 Reduction Structural
Task Train Renovation
Task Train
MH Inspection I Yes 9 ) MN Inspection
Smoke Testing
Yes
For purposes
of this
flowchart,
"overflow"
Na means an
sso,
Private Property Basement
Inspection
Backup,or
Prohibited
Bypass as
defined in
the Consent
Decree
Yes
No
Dyed.Water Testing of
Storm Sewers with
Concurrent CCTV for all
Positive Dye Tests ves
Yes
Ne - Yes
No
Page 5 of 9
U.S. & State of Iowa v. City of Waterloo
Appendix 6: Sanitary Sewer System Condition Assessment
N° Yes (1)-Severe(et al)"shall mean:
CCTV Sewers and those categories of defects
Rate Defects exhibiting the greatest level of
Observed in a; deterioration,the greatest risk of
accordance with the structural failure,and/or the
- greatest amount of I/I contribution,
City's defect rating such may be designated by the
program terms"Severe" "Large" "Heavy",
"Longitudinal-Multiple","Multiple-
Wider","Spiral-Wider"and/or
similar terms
Remediate Public
Sewer and Manhole Yes
Defects Rated"Severe No
(et al)"(1)
Output From Remediate Private
at Yes
Capacity it1' I. Sector I/1 Sources that
Analysis Task are Cost Effective(2)to
Train Eliminate
(2)"Cost-Effective"shall mean:The
Condition Remediation that is less
costly than the Capacity
�Y t Remediation that would otherwise
be required to transport the l/I that
`�- would be eliminated through
Condition Remediation
Output From Remediate Additional yes
Capacity ,Public Sewer and Manhole
Analysis Task Defects that are Cost-
Train Effective(2)to Eliminate
Develop Condition Remedial Measures Plan 4 N'
that Includes All Defects Rated"Severe(et
al)"(1);All Private Sector Defects
Determined to be Cost Effective(2)to
Eliminate;and,All Additional Defects
Detemaned to be Cost Effective(2)to
Eliminate
Ye- No
Through CMOM Program,
Input into Capacity Continue to Monitor Public
Re Task-- Sewer and Manhole Defects
Discovered but Not
Remediated
Page 6 of 9
Appendix 6
Sanitary Sewer System Condition Assessment Report Template
The following Template format is intended to expedite the City's effort to prepare Condition Assessments and to
expedite EPA review of those Assessments. EPA recognizes that some modifications in the Template format may
be necessary to match actual Assessment activities and findings. Use of this Template is at the City's option, but all
information herein is required unless the City demonstrates that such information is not applicable due to the
outcomes of the specific Condition Assessment activities performed.
I. Cover
II. Certification Declaration
[Required certification,with language specified by the Consent Decree,
signed by a responsible official of Waterloo]
III. Table of Contents
[List of sections,tables,figures and appendices included in this report]
IV. Acronyms and Abbreviations
[Definitions of abbreviations and acronyms included in this report]
V. Introduction
A. Purpose
This Report was prepared and submitted pursuant to Paragraph 19 of the
Consent Decree.
B. Regulatory Requirements
This Report summarizes Condition Assessment inspections completed by
Waterloo as required by Paragraphs 19 and 20 of the Consent Decree. These
Condition Assessment requirements include Gravity Main Sewer Inspections,
Manhole Inspections, Pump Stations Inspections and Force Main Inspections.
VI. System-Wide Inspection Activities
A. Inspection Method Overview
[Provide a brief description of each inspection method utilized by Waterloo;
with a reference to the Condition Assessment and Remediation Process and
Guidelines Appendix. Add a discussion of any new inspection technologies
utilized, if applicable]
Page 7 of 9
1
Appendix 6
Sanitary Sewer System Condition Assessment Report Template
B. Gravity Sewer Main Inspection Table
[Include a table showing the location of the inspections with upstream and
downstream manhole number,small diameter and large diameter pipe,
inspection method (CCTV, Pole Camera,Visual Inspection),and type of visual
inspection(Smoke testing, mechanical proofing, cleaning,dye testing).]
C. Gravity Sewer Main Inspection Status
Gravity Sewer Main Inspection Progress Summary
Asset Description Inspection Method Total Miles of Total miles in %Complete
Inspections Service Area
Completed
Gravity Sewer- Concrete CCTV or other approved
Pipe and Clay Pipe techniques
Installed Prior to 1973
Gravity Sewer- Clay Pipe Pole Camera, CCTV,or
Installed from 1973 other approved
through 1982 techniques
Pole Camera, CCTV or
other approved
techniques
Visual Inspection—Smoke
Testing
Gravity Sewer - Other
Pipe Visual Inspection— Mech.
Proofing
Visual Inspection—Sewer
Cleaning Findings
Visual Inspection— Dye
Testing
Service Area total
D. Manhole Inspection Status
Manhole Inspection Summary
Asset Description Inspection Method Number of Inspections %Complete
Manholes in Completed
Service Area
Service Area_Manholes Visual Inspection
Note 2:Includes manhole inspections since January 1,2012.
E. Pump Station Inspection Status
Pump Station Inspection Summary
Pump Station Name Service Area Scheduled Backup Power Overflow Storage
inspection MG
frequency
Page 8 of 9
Appendix 6
Sanitary Sewer System Condition Assessment Report Template
F. Force Main Inspection Status
Force Main Inspection Summary
Asset Description Inspection Total Miles of Total miles in %Complete
Method Inspections Completed Service Area
Force Main
VII. Categorization of Sewer Main and Manhole Condition
A. Guidelines
[Provide a brief description of the guidelines used for categorizing condition;
consistent with the Condition Assessment and Remediation Process and
Guidelines Appendix]
B. Condition Categorization Summary
Condition Categorization Summary Table
Condition Category Miles of Sewer Number of Pump Stations Force Mains
Mains Manholes
Category A—Severe
Category B—Medium
Category C—Light
VIII. Condition Assessment Results
A. Condition Assessment Guidelines
[Provide a brief description of the guidelines used for condition assessment
activities;consistent with the Condition Assessment and Remediation Process
and Guidelines Appendix. Provide a brief description of how Waterloo
applied the guidelines to develop the quantities of structural defects selected
for Remedial Measures Alternative Analysis,Monitoring(CMOM)and
Maintenance Analysis (CMOM).]
B. Condition Assessment Results
Condition Category Milesof Sewer Number of Pump Stations Force Mains
Mains Manholes
Category A—Severe
Category B—Medium
Category C—Light
Page 9 of 9
U.S. & State of Iowa v. City of Waterloo
Appendix 7: Hydraulic Model
Hydraulic Model
1. The hydraulic model is intended to provide the City with the ability to assess overall
Sanitary Sewer System performance and track wastewater flow patterns across the City. The
hydraulic model is expected to:
a. help identify capacity-restricted existing Sanitary Sewer System components,
b. help develop and evaluate Sanitary Sewer System remedial measures alternatives
to resolve constraints that result in a lack of Adequate Capacity,
c. help develop final sizing parameters for capacity remedial measures selected by the
City for implementation,
d. help evaluate the overall hydraulic effects of Sanitary Sewer System capacity
remedial measures constructed to resolve hydraulic constraints, and
e. help analyze the hydraulic impacts of increased Infiltration/Inflow resulting from
Sanitary Sewer System aging and of growth across the City.
2. Hydraulic model development shall be performed in accordance with sound engineering
practices taking into consideration the following: Sewer System Infrastructure Analysis and
Rehabilitation, EPA/625/6-911030;Existing Sewer Evaluation and Rehabilitation, WEF MOP
FD-6, 3rd edition, 2009;Prevention and Control of Sewer System Overflows, WEF MOP FD-
17, 3rd edition, 2011 (hereinafter"the Manual");A Guide to Short Term Flow Surveys of
Sewer Systems, WRC Engineering, 1987;the Code of Practice for the Hydraulic Modeling of
Sewer Systems Version 3.001, December 2002,prepared by The Chartered Institution of Water
and Environmental Management(CIWEM-formerly WaPUG).
3. The City shall continue to use XP SWMM 2014 by XP Solutions as the software
platform for the computerized hydraulic model.The use of more recently released versions of
XP SWMM software or the use of other technically comparable alternative software platforms for
the model will be at the sole discretion of the City. The City shall provide written notice to EPA
of any changes in the brand or version of hydraulic modeling software from XP SWMM 2014
prior to employing that software for Sanitary Sewer System analysis.
4. The City shall update its Sanitary Sewer System hydraulic model as necessary to include
Page 1 of 3
U.S.& State of Iowa v.City of Waterloo
Appendix 7: Hydraulic Model
all City owned Pump Stations,Force Mains, Equalization Facilities or other hydraulic control
facilities, and documented Gravity Sewer Lines 8-inches and larger, based upon current
physical parameter data and other hydraulic property information known to the City. The
hydraulic model shall also include all additional Gravity Sewer Lines as necessary to extend the
hydraulic model at least one Pipe Segment upstream of the locations of recurring wet-weather
overflows(SSOs, Building Backups and Prohibited Bypasses),where such information is known
and available to the City.
5. The City shall update, calibrate and verify the hydraulic model to accurately represent
the Sanitary Sewer System utilizing currently accepted engineering procedures. The hydraulic
model dry-weather calibration/verification process conducted for development of the final model
calibration report shall be based upon at least one weekly dry-weather calibration data set and one
weekly dry-weather verification data set(if rainfalls disrupt the collection of continuous weekly
periods of dry-weather flow data,the weekly calibration/verification data sets may be compiled from
dry-weather flow data collected on the appropriate days of the week that are not consecutive by
calendar). The hydraulic model wet-weather calibration/verification process conducted for
development of the final model calibration report shall be based upon at least three independent
precipitation event calibration data sets and one independent precipitation event verification
data set, including rainfall data, metered hydrographs, pump station flow data, and other
Sanitary Sewer System flow data as may be available. The independent rainfall events selected
for calibration and verification shall be based upon sound engineering judgement and shall be
of an appropriate combination of intensity and duration to raise peak flowrates in the Sanitary
Sewer System significantly. The variations of modeled flows(determined through the
hydraulic model verification process)from field-measured sanitary sewer flows shall,to the
extent practical, generally conform to the numeric ranges and other model performance criteria
presented in Table 5.2 of the Manual.
6. The Hydraulic Model shall provide a sufficient understanding of the response of the
City's Sanitary Sewer System to wet weather events to enable the City to identify appropriate
remedial measures to address capacity limitations identified in its Sewer System. In assessing
the capacity of the Sewer System,the City shall run the hydraulic model, under normal
groundwater levels,using the following analysis rainfall amounts and intensity time-
distributions in accordance with Rainfall Frequency Atlas Of The Midwest("Bulletin 71"),
Page 2 of 3
U.S.& State of Iowa v. City of Waterloo
Appendix 7: Hydraulic Model
dated 1992, prepared by the Midwestern Climate Center and the Illinois State Water Survey:
2-year/6-hour rainfall—2.18 inches total precipitation
5-year/6-hour rainfall—2.75 inches total precipitation
10-year/6-hour rainfall—3.23 inches total precipitation.
7. The City shall complete the initial development of an updated hydraulic model of its Sewer
System that has been calibrated to 2015 data no later than February 29,2016.
8. The City shall complete the development of the hydraulic model of its Sewer System,
using updated flow and rainfall data,with the results reported no later than August 31, 2016.
On or before that date, the City shall submit a final model calibration report containing the
following information:
a. A description of the hydraulic modeling software employed if different from XP
SWMM 2014.
b. Hydraulic model development activities,including: descriptions of the elements of the
Sewer System included in the hydraulic model; incorporation of the City's most recent
GIS data; and the City's efforts to determine actual pump station discharge capacities
that were incorporated into the hydraulic model.
c. Summary of flow metering and rainfall monitoring conducted for hydraulic model
calibration and verification.
d. Calibration/verification graphs or tabulations of model results for the developed model,
demonstrating that the variations between modeled and metered flows meet the
tolerances set forth in Table 5.2 of the Manual.
e. A list and summary of the Sewer System capacity constraints identified through analyses
of the rainfall events identified under Paragraph 6 of this Appendix that have or will be
included within the Sewer System Capacity Assessment activities.
Page 3 of 3
U.S. & State of Iowa v. City of Waterloo
Appendix 8: Sanitary Sewer System Capacity Assessment
Sanitary Sewer System Capacity Assessment
1. The City shall assess the capacity of the Sewer System as described herein in accordance
with the following schedule:
a. Service Areas 15 and 16 shall be assessed by September 30, 2016 and the results
reported, in accordance with Paragraph 7 of this Appendix, by December 31, 2016.
b. Service Areas 18 and 19 shall be assessed and results reported, in accordance with
Paragraph 7 of this Appendix, in the Master Plan to be submitted December 31, 2017.
c. Service Areas not assessed pursuant to paragraphs l.a or 1.b above shall be
assessed in accordance with the CMOM program and reported annually in accordance
with Paragraphs 43 and 44 of the Consent Decree.
2. During the Capacity Assessment,the City shall assess the existing and future capacity of
the Sewer System taking into consideration the process outlined in the attached Capacity
Assessment Process Flowchart.
3. The City shall assess the existing and future capacity of the Sanitary Sewer System to
convey predicted peak flows resulting from the 2-year, 5-year and 10-year rainfalls. The Sewer
System's performance during these three storm events shall be evaluated using the calibrated
and field-verified hydraulic model.The Capacity Assessment shall account for projected
population and flow rate growth for twenty(20)years following the Effective Date of this
Consent Decree.
4. The Capacity Assessment is designed to:
a. identify Service Areas with Inflow and Infiltration (I/I),which are causing and/or
contributing to SSOs, Building Backups,and Prohibited Bypasses;
b. identify and quantify sources of I/1 within the Service Areas; and
c. identify known SSOs, Building Backups and Prohibited Bypasses within each
Service Area.
5. Data Review and Management. In preparing the Capacity Assessment,the City shall
compare model output of wet weather SSOs,Building Backups and Prohibited Bypasses locations
and surcharging with known data concerning SSOs,Building Backups and Prohibited Bypasses,
sewage flows,and WWTP flows and capacity.Where there is a correlation between the model
and maintenance records/institutional knowledge,the City shall proceed in categorizing wet-
Page 1 of 8
U.S.& State of Iowa v. City of Waterloo
Appendix 8: Sanitary Sewer System Capacity Assessment
weather SSOs,wet-weather Building Backups and Prohibited Bypasses in a manner generally
consistent with the"Type A/B/C"classification approach reflected in the Capacity Assessment Process
Flow Chart.Other circumstances without a correlation should be scheduled for further evaluation
potentially with more flow monitoring in the vicinity ofthe problem area or under the CMOM program.
6. Using the results of the Capacity Assessment,the City shall categorize potential capacity
constraints following the priority criteria listed below. This list will be used as a guide for developing
remedial measure alternatives and scheduling the selected remedial measures, which shall be
presented in the Master Plan.
a. Priority criteria:
i. High Priority: Parts of the Sewer System where SSOs,wet-weather
Building Backups or Prohibited Bypasses have historically occurred.
ii. Moderate Priority: Parts of the Sewer System where modeling predicts
SSOs, wet-weather Building Backups and Prohibited Bypasses will occur
under present conditions,but such incidents have not historically occurred.
iii. Lower Priority: Parts of the Sewer System that modeling indicates are at or
near full capacity, such that SSOs, wet-weather Building Backups, or
Prohibited Bypasses may occur under future conditions.
7. The City's reports on the status of the Capacity Assessment activities, pursuant to
Paragraphs l.a and 1.b of this Appendix, shall provide all information required under the
Capacity Assessment Report Template as applicable to the specific assessment activities
performed by the City. The Capacity Assessment reports shall be submitted to EPA in
accordance with Section VII of the Consent Decree (Review and Approval Procedures).
Page 2 of 8
U.S.& State of Iowa v. City of Waterloo
Appendix 8: Sanitary Sewer System Capacity Assessment
Capacity Assessment
Process Flowchart
Capacity Remediation Task Train
Input into Condition
Assessment- -
Reduction Task Train.
ne
Review Sewer System
Compare Model Output of Wet-Weather Overflows performance Data In City
&Sewer Surcharging Locations with City Maintenance Records&
Maintenance Records and Institutional Knowledge. Institutional Knowledge to
Categorize as follows: Identify Locations of Wet-
Type A-most likely a capacity 550 Weather Overflows and
Type B-most likely maintenance related Wet-Weather Sewer
Type C-clearty NOT capacity related Surcharging
Re-Calibrate Model-Conduct
Additional Flow-Monitoring in the
—♦t Vicinity of the Model locations off " For purposes of this flowchart,
Wet-Weather Overflows and/or 'overflow'means an 550,Basement
Sewer Surcharging if Necessary Backup,or Prohibited Bypass as
defined in the Consent Decree
yes
ro
Yes
Potential Capacity Constraints
Nigh Priority-Parts of the Sewer System where Wet-Weather SSOs,Building Backup or Prohibited Bypasses have
historically occurred.
Moderate Priority-Parts of the Sewer System where modeling predicts Wet-Weather SSOs,Binding Backups and
yes Prohibited Bypasses will occur under present conditions,but such incidents have not historically occurred.
[0. Lower Priority-Parts of the Sewer System that modeling indicated are at or near full capacity,such that Wet-Weather
ssos,Building Backups,or Prohibited Bypasses may occur under future conditions.
The list above represents criteria for the City prioritizing the potential capacity constraints that may warrant field
investigation-This list shall be used to prioritize field investigations,in general starting at the top of the list,and working
towards lower priorities as higher priority field investigations are concluded.The City shall update as necessary potential
Capacity Constraints as new information becomes available or adjustments to the model are made.
1
Develop
Capacity
Remedial
Measures
Alternatives
•
Conduct Iterative Analysis Comparing Capacity Output from
Remedial Measures Alternatives to Potential Condition Condition
Remedial Measures to Identify those Capacity and y t_vi
Condition Measures Required to Eliminate Wet- RFd11CtlprsTeSk
Weather Overflows for 2-Yr,5-Yr&10-Yr Rainfalls
Based upon Cost Versus Environmental Benefit ° T(3itt
y W
Input into Contrition Develop Final Capacity
Asxsment-l/I Remedial Measures in
RedtardmTaskTrain Master Plan
Page 3 of 8
Appendix 8
Sanitary Sewer System Capacity Assessment Report Template
The following Template format is intended to expedite the City's effort to prepare Capacity Assessment Report and
to expedite EPA review of that Report. EPA recognizes that some modifications in the Template format may be
necessary to match actual Capacity Assessment results. Use of this Template is at the City's option,but all
information herein is required unless the City demonstrates that such information is not applicable due to the
outcome of the Capacity Assessment.
I. Cover
[Denote the date of submittal and Update Number(e.g. Original submission,
Update 1, Update 2, etc.)]
II. Certification Declaration
[Required certification,with language specified by the Consent Decree,
signed by a responsible official of Waterloo. A new certification is required
for each submitted update.]
III. Table of Contents
[List of sections,tables,figures and appendices included in this report]
IV. Acronyms and Abbreviations
[Definitions of abbreviations and acronyms included in this report]
V. Introduction
A. Purpose
This Report was prepared and submitted pursuant to Paragraphs 24 and 25 of
the Consent Decree.
B. Regulatory Requirements
This Report summarizes Capacity Assessment activities pursuant to
Paragraphs 24 and 25 of the Consent Decree. These Capacity Assessment
requirements include wet-weather SSO, Building Backup and Prohibited
Bypass verification, hydraulic modeling evaluation and field investigation
activities.
VI. Wet-Weather Related SSO, Building Backup and Prohibited Bypass Categorization
A. Guidelines
Page 4 of 8
Appendix 8
Sanitary Sewer System Capacity Assessment Report Template
[Provide a brief description of the guidelines used;with a reference to the
Capacity Assessment Process Flowchart,to identify Type A,B,and C SSOs,Building
Backups and Prohibited Bypasses in the Service Area.Ultimately,continue to update this
process description and resulting Type A-C SSOs,Building Backups and Prohibited
Bypasses for each Service Area that is evaluated.]
B. Wet-Weather SSO,Building Backup and Prohibited Bypass Categorization Summary
Wet Weather SSO,Building Backup and Prohibited Bypass Categorization
Type Number of SSOs,Building Backups and Prohibited
Bypasses
Type A—Most likely capacity-related
Type B—Most likely maintenance-related
Type C—Clearly not capacity related
Total
C. Map of Wet-Weather SSOs, Building Backups and Prohibited Bypasses
[Include a single,legible map showing the location of Type A, B,and C wet-
weather SSOs,Building Backups and Prohibited Bypasses,a map showing the
location of Type A wet-weather SSOs,Building Backups and Prohibited Bypasses,a
map showing the location of Type B wet-weather SSOs,Building Backups and
Prohibited Bypasses,and a map showing the location of Type C wet-weather
SSOs,Building Backups and Prohibited Bypasses.]
VII. System-wide Hydraulic Modeling Evaluation
A. Model Overview
[Provide a brief description of the model including software and existing
population scenario,consistent with the Hydraulic Model Appendix and
Capacity Assessment Process Flowchart.]
B. Model Description
[Include a written summary of the pipes included in the model and an
affirmation that the model sewers conform to the requirements of the CD.]
C. Model Setup and Calibration
[Provide a summary of entire model setup,calibration,and verification
process].
Page 5 of 8
Appendix 8
Sanitary Sewer System Capacity Assessment Report Template
D. Prioritization of Potential Capacity Constraints
[Provide a brief description of the guidelines used to prioritize potential capacity
constraints;consistent with the Capacity Assessment Process Flowchart].
Example of a Potential Capacity Constraints Summary
Category Number of Potential
Capacity Constraints
High Priority: Parts of the Sewer System where SSOs, Building
Backup or Prohibited Bypasses have historically occurred.
Moderate Priority: Parts of the Sewer System where modeling
• predicts SSOs, Building Backups and Prohibited Bypasses will occur
under present conditions, but such incidents have not historically
occurred.
Lower Priority: Parts of the Sewer System that modeling indicates
are at or near full capacity, such that SSOs, Building Backups, or
Prohibited Bypasses may occur under future conditions.
Other Priority Areas:(describe)
Total
E. Map of Potential Capacity Constraints
[Include a map showing potential Capacity Constraints for all Priority Categories.
Include separate maps for each Priority Category showing the location of
Potential Capacity Constraints.]
VIII. Field lnvestigationsof Potential CapacityConstrai nts
A. Guidelines
[Provide a brief description of the guidelines used for selecting the type of
field investigation technique for each potential capacity constraint;
consistent with Capacity Assessment Process Flowchart.]
B. Field Investigation Status
Completed Field Investigations
Technique Number of Potential Capacity Constraints
Priority 1 Priority 2 Priority 3 Priority 4
Flow Metering
Smart Covers
Chalking
Visual Inspection—Smoke Testing
Visual Inspection— Mechanical
Proofing
Page 6 of 8
Appendix 8
Sanitary Sewer System Capacity Assessment Report Template
Visual Inspection—Sewer
Cleaning Findings
Visual Inspection—Dye Testing
Other-describe(if
applicable)
Monitor in Future per Capacity
Assessment and Remediation
Process and Guidelines Appendix
(CMOM)
Total
In-Progress Field Investigations
Technique Number of Potential Capacity Constraints
Priority 1 Priority 2 Priority 3 Priority 4
Flow Metering
Smart Covers
Chalking
Visual Inspection—Smoke Testing
Visual Inspection—
Mechanical Proofing
Visual Inspection—Sewer
Cleaning Findings
Visual Inspection—Dye Testing
Other-describe(if applicable)
Total
C. Completed Field Investigations
[Include a table for each Priority Category showing the upstream and
downstream manhole numbers of each field investigation by technique.]
D. In-Progress Field Investigations
[Include a table for each Priority Category showing upstream and downstream
manhole numbers of each field investigation by technique.
IX. Capacity Assessment Results
A. Capacity Assessment Guidelines
[Provide a brief description of the guidelines used for assessing field
investigation results;consistent with Capacity Assessment Flowchart and those
included in the Master Plan.
B. Capacity Assessment Results
Page 7 of 8
Appendix 8
Sanitary Sewer System Capacity Assessment Report Template
Capacity Assessment Result Number of Potential Capacity Constraints
Remedial Measures Alternatives Analysis
Monitor in the future CMOM program per
Capacity Assessment Process Flowchart.
Not a Capacity Constraint
Total
C. Capacity Assessment Results
[Include a color-coded map showing the location of the Capacity Assessment
Results. In addition, a table summarizing results of Capacity Assessment,
including upstream and downstream manhole number. Show a clear path as
to how identified and verified capacity constraints were either included in
the Master Plan, monitored in the CMOM program, or determined not to be
a capacity constraint.]
Page 8 of 8
U.S.& State of Iowa v. City of Waterloo
Appendix 9: Sanitary Sewer System Master Plan
Sanitary Sewer Master Plan
1. The Master Plan shall present the City's plan to address the issues identified in the
targeted Sanitary Sewer System Condition and Capacity Assessments and shall provide
the information required under the attached Master Plan Template as applicable to
the remedial measures proposed by the City.
2. The Master Plan shall contain a Condition Assessment section and a Capacity
Assessment section. Each of these sections shall include a description of the
guidelines applied in performing analysis of remedial measures alternatives,
including those used to select monitoring or maintenance results using the cost-
benefit approach for the targeted storm conditions outlined in Appendix 8.
3. The Master Plan shall include a summary of remedial work already performed at the
time of the report, as well as a schedule for the work described in the Master Plan.
Page 1 of 8
Appendix 9
Sa Sanitary Sewer System Master Plan Template
The following Template format is intended to expedite the City's effort to prepare the Master Plan and to expedite
EPA review of that Plan. EPA recognizes that some modifications in the Template format may be necessary to match
actual Plan developments. Use of this Template is at the City's option, but all information herein is required unless
the City demonstrates that such information is not applicable due to the outcome of the Master Plan development.
I. Cover
II. Certification Declaration
[Required certification, with language specified by the Consent Decree,signed
by a responsible official of Waterloo]
III. Table of Contents
[List of sections, tables,figures and appendices included in this report]
IV. Acronyms and Abbreviations
[Definitions of abbreviations and acronyms included in this report]
V. Condition Assessment Introduction
A. Purpose
This Plan was prepared and submitted pursuant to Paragraph 26 of the
Consent Decree.
B. Regulatory Requirements
This Section summarizes Waterloo recommended Condition Remedial
Measures that have been prioritized and selected in accordance with
Appendix 6 to address verified structural defects in the Waterloo sanitary
sewer system that cause or significantly contribute to Condition-related
SSOs, Building Backups and Prohibited Bypasses. This Section describes
Waterloo's plans to implement the selected Condition Remedial Measures
on a balanced annual basis during the remaining term of this Decree.
Waterloo has prioritized and selected these Condition Remedial Measures
based on appropriate factors reflected in Paragraph 19 and in Appendix 6 of
the Consent Decree and in accordance with the requirements of the Consent
Decree. The implementation time-frames in this section reflect practical
planning requirements such as those stated in Paragraphs 26 through 28 of
the Consent Decree.
VI. Summary of Condition Assessment Summary Report
Page 2 of 8
Appendix 9
Sa Sanitary Sewer System Master Plan Template
[Brief summary of the Condition Assessment Summary Report and how it
relates to this Plan].
VII. Remedial Measures Alternatives Analysis
A. Guidelines for Alternatives Analysis
The Plan for Condition Remedial Measures follows Waterloo completion of the
Condition Remedial Measures Alternatives Analysis as described in Appendix 6
of the Consent Decree.
B. Remedial Measures Alternatives Analyses Results
[Provide a brief description of the guidelines used for performing alternatives
analysis;consistent with Condition Assessment and Remediation Process and
Guidelines Appendix. Include a description of guidelines used to select
monitoring or maintenance results.]
Results of Completed Remedial Measures Alternatives Analyses
Miles of Number of
Result Gravity Sewer Number of Manholes
Gravity Main
Main Pipe
Sewed Segments
Replace2,3
Rehabilitate3,4
Repair3,4
Monitoring
Maintenance Analysis
Other(Specify)
Totals:
Note 1: Full pipe length is included in mileage.
Note 2: Includes conventional open-cut replacement,replacement by tunneling and
replacement by pipe-bursting.
Note 3:Approach for actual implementation may be different than alternatives analysis result
Appendix 6(Condition Assessment).
Note 4:Repairs include spot repairs or remediation of a short section of the pipe segment using
trenchless or open-trench remediation. Rehabilitation includes trenchless sewer remediation from
manhole to manhole such as CIPP lining or slip-lining.
Page 3 of 8
Appendix 9
Sanitary Sewer System Master Plan Template
VIII. Remediation Completed
A. Remedial Measures Progress
[Summarize the mileage and number of manholes for which Condition
Remedial Measures have been completed prior to submittal of this report.]
Remedial Measure Total Mileage
Technique
Sewer Mains Replace
(miles)la
Rehabilitate
Repair
Manholes Replace
(number)2
Rehabilitate
Repair
Pump Stations Replace
(number)
Rehabilitate
Repair
Force Mains Replace
(miles)la
Rehabilitate
Repair
Note 1:Full pipe length is included in mileage.
Note 2:Repairs include spot repairs or remediation of a short section of the pipe segment using
trenchless or open-trench remediation. Rehabilitation includes trenchless sewer remediation from
manhole to manhole such as CIPP lining or slip-lining.
Page 4 of 8
Appendix 9
Sanitary Sewer System Master Plan Template
IX. Master Plan
A. Anticipated Condition Remediation Timeframes
(Summarize target remediation quantities for completion each year.]
Remedial Calendar Calendar Calendar Calendar Calendar Total
Measure Years Years Years Years Years
Technique 2018-20 2021-23 2024-26 2027-29 2030-32
Sewer Replace
Mains
(miles)' Rehabilitate
Repair
Manholes Replace
(number)
Rehabilitate
Repair
Pump Station Replace
(number)
Rehabilitate
Repair
Force Mains Replace
(miles)'
Rehabilitate
Repair
Note 1:Full pipe length is included in mileage
Note 2:Waterloo may make day-to-day operational changes to Remedial Measures consistent with the
Consent Decree,including Appendix 6 of the Consent Decree.
B. Condition Remediation Project List
Remediation Project List
Project Name Completion Date Service Area Project description
Page 5 of 8
•
Appendix 9
Sanitary Sewer System Master Plan Template
X. Capacity Assessment Introduction
A. Purpose
This section was prepared and submitted pursuant to Paragraph 24 of the
Consent Decree.
B. Regulatory Requirements
This section summarizes Waterloo's recommended Capacity Remedial
Measures that have been prioritized and selected in accordance with Appendix
8 to address Capacity Constraints in the Waterloo sanitary sewer system
identified through flow metering and hydraulic modeling that cause or
significantly contribute to Capacity-related SSOs. This section describes
Waterloo's plans to implement the selected Capacity Remedial Measures.
Waterloo has prioritized and selected these Capacity Remedial Measures
based on appropriate factors to achieve the goals of the Decree.
XI. Summary of Capacity Assessment Summary Report
[Brief summary of the Capacity Assessment Summary Report and how it relates
to this Plan.]
XII. Remedial Measures Alternatives Analysis
C. Guidelines for Alternative Analysis
The Plan for Capacity Remedial Measures follows Waterloo's completion of the
Capacity Remedial Measures Alternatives Analysis as described in Appendix 8 of
the Consent Decree.
D. Remedial Measures Alternatives Analysis Results
[Provide a brief description of the guidelines used for performing alternatives
analysis. Include a description of guidelines used to select continued monitoring
results.]
Results of Remedial Measures Alternatives Analyses
Remedial Measures Alternatives Analysis Result* Number of Potential Capacity Constraints
Re-route a portion of upstream wastewater flows
Reduce flows entering the sanitary sewer system
Reduce inflow
Reduce infiltration
Increase conveyance capacity
Upstream flow detention facilities
Continued monitoring
Other(Specify)
Page 6 of 8
Appendix 9
Sanitary Sewer System Master Plan Template
Totals:
*Note:Some Capacity Constraints may require more than one remedial measure technique. The
predominant remedial measure technique will prevail for reporting purposes.
E. Alternatives Analysis Results
[Include a color-coded map showing the location of each type of result. In addition,
a summary table should be included, with upstream and downstream manhole
number of each segment considered as part of analysis.]
XIII. Remediation Completed
A. Capacity Remedial Measures Progress
[Summarize the mileage for which Capacity Remedial Measures have been
completed prior to submittal of this report.]
Completed Capacity Remedial Measures
Remedial Measure Technique Total Mileage
Sewer Mains Re-route a portion of upstream wastewaterflows
(miles)' Reduce flow entering Sewer System
Reduce inflow
Reduce infiltration
Increase conveyance capacity
Upstream flow detention facilities
Other(specify)
Manholes Replace
(number) Rehabilitate
Repair
Pump Stations Replace
(numbers) Rehabilitate
Repair
Force Mains Replace
(miles)' Rehabilitate
Repair
Footing Drain Disconnections
Note 1:Full pipe length is included in mileage.
Note 2:Some Capacity Constraints may require more than one remedial measure technique. The
predominant remedial measure technique will prevail for reporting purposes.
B. Table of Capacity Remedial Measures Completed
[Include a Table summarizing completed remedial measures by remediation
method and asset type(small diameter pipe, large diameter pipe, and manholes)
that identifies and distinguishes between replaced and repaired manholes.]
Page 7 of 8
Appendix 9
Sanitary Sewer System Master Plan Template
XIV. Master Plan
A. Anticipated Capacity Remediation Timeframes
[Summarize target remediation quantities for completion each year. Include a
list of Lift Stations that require capacity upgrades.]
Anticipated Remediation Timeframes
Remedial Calendar Calendar Calendar Calendar Calendar Total
Measure Years Years Years Years Years
Technique 2018-20 2021-23 2024-26 2027-29 2030-32
Re-route a
Sewer Mains portion of
(Number of upstream
constraints Reduce flow
addressed) entering
Reduce inflow
Reduce infiltration
Increase
conveyance
Upstream
flow
Other(specify)
Manholes Replace
(number) Rehabilitate
Repair
Pump Stations
(number)
Force Mains
(Number of
constraints
Other(e.g.,
footing drain
remediation)
Note 1:Waterloo may make changes to Remedial Measures consistent with the Consent Decree.
Note 2:Some Capacity Constraints may require more than one remedial measure technique. The
predominant remedial measure technique will prevail for reporting purposes.
B. Capacity Remediation Project List
Capacity Remediation Project List
Project Name (including Target Completion Service Area Project Description
MH numbers,where Date
applicable)
Page 8 of 8