VILLAGE OF WHITEFISH BAY CAPACITY, MANAGEMENT, OPERATIONS, MAINTENANCE (CMOM) PLAN

Prepared By: Superior Engineering, LLC S75W13139 Oxford Court Muskego, WI 53150 (414) 235-9726

Version 3 February 25th, 2010

TABLE OF CONTENTS

Manual No. 1 SECTION 1 Overview ..............................................................................................................1 SECTION 2 Management Plan................................................................................................4 SECTION 3 Operation And Maintenance Plans14 SECTION 4 Capacity Plan 18 SECTION 5 - Overflow Response Plan .20 SECTION 6 - Condition Assessment Program .22 SECTION 7 - Communication Plan 23 SECTION 8 Audit Plan...24 APPENDIX A Reference Stipulation - Satellite Municipalities APPENDIX B Reference Stipulation Milwaukee Metropolitan Sewerage District APPENDIX C Reference CMOM Strategic Plan January 2008 APPENDIX D - Overflow Response Plan 1. Table D-1 Sanitary Sewer Overflow and Monitored Sites 2. Table D-2 Emergency Contact Notification 3. Table D-3 Emergency Contractor Notification 4. Table D-4 Mutual Aid Table APPENDIX E - Forms 1. 2. 3. 4. 5. 6. 7. Sanitary Sewer Overflow or Bypass Notification Summary Report Form 3400-184. Lateral Root Notice to Homeowners Sewer Cleaning Form Public Works Service Request Form Manhole Inspection Form Root Cause Failure Analysis Form MS4 Stormwater Permit Form 3400-191

APPENDIX F Standard Operating Procedures (SOP)

TABLE OF CONTENTS1. Wet Weather SOP 2. Critical Manhole Locations 3. Sanitary Sewer Maintenance Procedures SOP APPENDIX G References 1. 2. 3. 4. 5. 6. 7. Table G-1 Annual Performance Measurements 2009 Cleaning and Root Cutting Schedule 2009-2011 Capital Improvements Map Sanitary Sewer Sanitary Sewer Easements Critical Locations in the Village Sanitary Sewer Seal Detail Modeled Sanitary Sewer System Schematic 2006

SECTION 1 - OVERVIEW1.1 Background and Information

The Village of Whitefish Bay is located in Milwaukee County. The Village serves approximately 14,000 people through its sanitary sewer system which consists of 204,336 linear feet of 8-inch to 18-inch diameter sanitary sewers and 1 manholes. There are no lift stations in the Village. The wastewater from the Village collection system discharges to the Milwaukee Metropolitan Sewer District (District) via several Metropolitan Interceptor Sewer (MIS) connections. The District is responsible for treating the wastewater A Capacity, Management, Operations and Management (CMOM) Plan is required to comply with the Satellite Stipulation between the State of Wisconsin and the Village of Whitefish Bay (State of Wisconsin v. Milwaukee Metropolitan Sewerage District, et. al. Case No. 2005-CS000013) as well as the stipulation entered between the State of Wisconsin and the District (Stipulation State of Wisconsin v. Milwaukee Metropolitan Sewerage District. Case No. 02CS-2701). Copies of the applicable portions of the stipulations are included in Appendices A and B, respectively. The overall intent of the CMOM Plan is to reduce sanitary sewer overflows (SSOs) in accordance with the regulations. 1.2 CMOM Program Objectives

The Wisconsin Department of Natural Resources (DNR) defines a CMOM program that achieves these primary objectives: 1. Ensures that communities have adequate wastewater collection capacity. 2. Improves the operation and performance of the municipal sanitary sewer collection system. 3. Evaluates areas of excessive inflow of precipitation or groundwater into the system. 4. Conducts maintenance and repairs needed to prevent problems. 5. Reduces the frequency and occurrence of sewer overflows and basement backups. 6. Provides more effective public notification when overflows do occur. In addition to these objectives, an effective CMOM program also: 1. Protects human health including drinking water, swimming, blood-born pathogens, fishing 2. Protects the local economy by preventing property damage, beach closures, and enhancing the fishing industry 3. Protect infrastructure investment by properly maintaining the sewers to reduce emergency repairs and extend the system life

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SECTION 1 - OVERVIEWFor further information on the background of a CMOM Plan and components, reference the CMOM Strategic Plan, January 2008 located in Appendix C. 1.3 CMOM Program Components

The CMOM Plan includes the following components: 1.4 Section 2 Management Plan Section 3 Operation and Maintenance (O&M) Plan Section 4 Capacity Plan Section 5 Overflow Response Plan (ORP) Section 6 Condition Assessment Program Section 7 Communications Plan Section 8 Audit Plan Definitions

For the purpose of this document the following definitions pertain: 1. CMOM Capacity, Management, Operations and Maintenance. A program to efficiently operate and maintain collection system assets to minimize performance failures and overflows. 2. Collection System is defined as the Village sanitary sewer system including sanitary sewers, manholes and associated equipment. 3. DNR means the Wisconsin Department of Natural Resources 4. DNR Chapter NR 110 Register May 2001, No. 545 Sewerage Systems NR 110. State of Wisconsin rules for sewerage systems. 5. District is the Milwaukee Metropolitan Sewerage District 6. Infiltration definition from Wisconsin DNR Chapter NR 110 - means water other than wastewater that enters a sewerage system (including sewer service connections) from the ground through such sources as defective pipes, pipe joints, connections, or manholes. Infiltration does not include, and is distinguished from, inflow. 7. Inflow definition from Wisconsin DNR Chapter NR 110 - means water other than wastewater that enters a sewerage system (including sewer service connections) from sources such as roof leaders, cellar drains, yard drains, area drains, foundation drains, drains from springs and swampy areas, manhole covers, cross connections between storm sewers and sanitary sewers, catch basins, cooling towers, storm waters, surface runoff, street wash waters, or drainage. Inflow does not include, and is distinguished from, infiltration. 8. I/I is the abbreviation for Infiltration/Inflow 9. Sanitary sewer overflow (SSO) is a condition whereby untreated sewage from the Village sanitary sewerage collection system is discharged into the environment prior toFebruary 25t h

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SECTION 1 - OVERVIEWreaching treatment facilities thereby escaping wastewater treatment. It is also considered a discharge of sewerage to waters of State. When caused by rainfall it is also known as wet weather overflow. SSO is also referred to as confirmed sewage spill, sewer overflow, or overflow. 10. Satellite Municipality is a municipality that is served by the District. The Village of Whitefish Bay is considered a satellite municipality. 11. Stipulation. Satellite Stipulation between the State of Wisconsin and the Village of Whitefish Bay. See Table 1-1 for a summary of the Village requirements. 12. Village Village of Whitefish Bay 1.5 Stipulation Summary

As noted previously, the Villages Stipulation with the State of Wisconsin is included in Appendix A. Some of the general provisions required under the Stipulation are outlined in Table 1-1. Table 1-1 Stipulation Summary Village of Whitefish Bay Section No. 17 18 19 20 21 22 31 Description Flow Monitoring and Rain Gauges District Enforcement of Sewer Use Ordinances Defects 2010 Limited SSES Study Inspect Manholes for Ponding Inspect Manholes on a five year basis CMOM Plan Submit SSO investigation for the SSOs at N. Newhall & E. Chateau Place and N. Diversey Blvd and E. Lancaster Avenue Deadline Ongoing Ongoing 12/31/2006 9/30/2006 6/30/2006 6/30/2009 1/31/2007 Complete Ongoing Annually Yes Yes Annually Draft May 2009 Yes

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SECTION 2 MANAGEMENT PLAN2.1. Background and Information A Management Plan describes the approach that the Village is undertaking to implement their CMOM Plan. The Management Plan consists of the following components. 1. Mission Statement 2. Goals 3. Organization 4. Management of Assets 5. Customer Service 6. Legal Authority 7. Fiscal 8. Data Management 9. Standard Design, Construction and Inspection 10. Training 11. Performance Measurements 2.2. MISSION STATEMENT The Village of Whitefish Bay developed a mission statement for their CMOM Program.

MISSION STATEMENTTo Cost Effectively Collect And Convey All Of Our Customers Wastewater In Accordance With Applicable Law. To protect the Health, Safety and Overall Environment of our Community.

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SECTION 2 MANAGEMENT PLAN2.3. GOALS The Village of Whitefish Bay strives for continuing and long term goals. Note that the goals in BOLD are required by District. See Table 2-5 linking goals with performance measures 1. Comply with WPDES permit 2. Minimize the occurrence of problematic overflows 3. Improve or maintain system reliability 4. Maintain assets cost-effectively through a rehabilitation and replacement program based on condition assessment 5. Provide first-class customer service 6. Reduce the potential threat to human health from sewer overflows 7. Protect collection system worker health and safety 8. Provide adequate capacity to convey peak flows 9. Manage Infiltration and Inflow 10. Operate a continuous CMOM Program 2.4. Organization Structure The Village owns and operates the wastewater collection system and currently does not have one full-time person assigned to the Collection Systems due the size of the community. To efficiently execute a CMOM program, it is necessary to identify employees that are responsible to implement the CMOM programs and to report sanitary sewer overflows. The Village will review staffing and out-sourcing services on a regular basis to determine if the CMOM Program is properly administered. The different program elements are managed as follows: See Table 2-1 for Village staff responsibilities and Figure 2-1 for the Village organization chart as it relates to the collection system.

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SECTION 2 MANAGEMENT PLANTable 2-1 Village Staff Responsibilities Title Village Manager Responsibilities Reports to the Village Board and manages all personnel, procurement, budget and overall operation of Village activities including the collection system. Responsible for CMOM Program. Is also responsible for the Collection Systems and all other functions of the DPW. Manages special projects including collection system projects Responsible for maintaining maps and other documents for the Village Responsible for managing Service Workers . Responsible for day-to-day activities in the field Responsible for cleaning and inspecting the sewers and other maintenance activities

Director of Public Works Assistant Village Engineer Engineering Technician DPW Superintendent Crew Leader Service Workers

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SECTION 2 MANAGEMENT PLAN2.5. Management of Assets Managing assets cost-effectively is a key CMOM program goal. 2.5.1. The Village has a comprehensive Capital Improvements Plan which is updated on an annual basis. The Village also has a three year sanitary sewer improvement plan that identifies specific projects to be completed. See Plan in Appendix G. 2.5.2. Village currently uses paper forms to track all activities. An example of each form can be found in Appendix E. The Village reviews and updates these forms on a regular basis. 2.5.3. Maps 2.5.3.1. The Village has updated their sanitary sewer map showing key assets including sewers and manholes. 2.5.3.2. The Village tracks many maintenance activities using sewer maps. These maps can be found in Appendix G. 2.5.4. Operation and Maintenance Programs See Section 3 for more details. 2.5.5. Condition Assessment Program. The Village currently has a program to evaluate the condition of the Village assets. This assessment is used to budget and plan for upcoming rehabilitation, repair and replacement programs. See Section 6 for more details. 2.5.6. Equipment and Spare Parts. To perform routine operations and maintenance, respond to emergencies and prevent sanitary sewer overflows, it is critical to have adequate equipment. In addition, spare parts for certain equipment items have been identified for emergencies. A list of equipment and spare parts that the Village owns and maintains can be found in Table 2-2.

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SECTION 2 MANAGEMENT PLAN

Table 2-2 Village Of Whitefish Bay Equipment And Spare Parts Description EQUIPMENT Sewer Combo Truck Inspection Truck Camera Portable Pump Portable Pump Portable Generator Aries Pathfinder Wacker Wacker None VacCon 1 9 cubic yard debris box 1 Pan and tilt - wheel driven for 6-24" pipe 2 4", 16HP 705 gpm 1 2 3", 8 HP, 425 gpm 2007 1998 Mfg/ Model Qty Capacity/Size Year Purchased

2.5.7. The Village has also identified critical sewers in their system. These are identified below and in Table 2-3 Sanitary Sewer Overflow and Monitored Sites. North Lake Drive Sewer Lydell Sewer Santa Monica Road Sewer Silver Spring Sewer Hampton Road Sewer

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SECTION 2 MANAGEMENT PLAN

Table 2-3 Village of Whitefish Bay Sanitary Sewer Overflow and Monitored Sites Manhole No. Manhole Location Site Type Receiving Point Description WB 16 WB 20 WB 1 WB 6 WB 7 WB 9 WB14 WB 13 WB 19 WB 26 WB 18 WB 23 MH 157 MH 91 MH 88 MH 162 Circle Drive (near public walk to Marlborough) Lake Drive @ Lake View Montclair & Kent Montclair & Bayridge Montclair & Santa Monica Montcalir &Berkeley Montclair & Lake Dr Monrovia & Lake Diversey & Lancaster Sheffield & Hampton Newhall & Fairmount Oakland & Lake Dr Wilshire & Cumberland Newhall & Chateau Lexington & Idlewild Wilshire & Cramer Overflow Site Valved Overflow Site Duck Bill Valve Overflow Site Gravity Pipe Overflow Site Gravity Pipe Overflow Site Gravity Pipe Overflow Site Gravity Pipe Overflow Site Gravity Pipe Overflow Site Valved Overflow Site Gravity Pipe Overflow Site Valved Overflow Site Gravity Pipe Overflow Site Gravity Pipe Overflow Site Gravity Pipe Overflow Site Gravity Pipe Monitored Site Portable Pump Monitored Site Portable Pump Storm Sewer on Circle, to Lake Michigan (Silver Spring Outfall) Storm Sewer on Lake Dr, to Lake Michigan (Silver Spring Outfall Storm sewer on Montclair, to Lake Michigan (outfall n/o Klode Park) Storm sewer on Montclair, to Lake Michigan (outfall n/o Klode Park) Storm sewer on Montclair, to Lake Michigan (outfall n/o Klode Park) Storm sewer on Montclair, to Lake Michigan (outfall n/o Klode Park) Storm sewer on Montclair, to Lake Michigan (outfall n/o Klode Park) Storm sewer on Montclair, to Lake Michigan (outfall n/o Klode Park) Storm Sewer on Lancaster, to Milwaukee River @Estabrook Park Storm Sewer on Hampton, to Milwaukee River @Estabrook Park Storm Sewer on Newhall, to Lake Michigan (Buckley Park Outfall) Storm Sewer on Lake Dr, to Lake Michigan (Buckley Park Outfall) Storm Sewer on Wilshire, to Lake Michigan (Buckley Park Outfall) Storm Sewer on Newhall, to Lake Michigan (Buckley Park Outfall) Storm Sewer on Idlewild to Lake Michigan (Silver Spring Outfall) Storm Sewer on Cramer, to Lake Michigan (Buckley Park Outfall)

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SECTION 2 MANAGEMENT PLANHow the Village delivers service to its customers is critical for effective CMOM program. The program is monitored based on how quickly can the Village respond and resolve the problem. Tracking these issues is critical to determine problems in the field including problems related to customers laterals (customer obligation) versus Village. The Village has a Public Works Service Request form and is using this as a tool to address problem areas and ensure that the work is documented. A copy of this form can be found in Appendix E. The Village website is used to inform their customers of Staff contacts, upcoming projects, ordinances and newsletters. See Section 7 Communication Plan for other details related to communications. 2.7. Legal Authority Legal authority consists of the Village codes and ordinances and the enforcement of codes and ordinances. The Village reviews and updates their ordinances on a regular basis. All ordinances are available on the Village website. The Village currently has the following ordinances: Sanitary Code Chapter 10 Plumbing Code Chapter 13 Maintenance of Property Chapter 18 2.7.1. Sewer Use/Sanitary and Plumbing Codes 2.7.1.1. The Village will review their ordinance on a regular basis to modify as necessary revised regulations and to ensure clear water from other sources is not entering the collection system. The ordinance evaluates the use of public and private sewers and drains in to the public sewerage system within the Village. 2.7.1.2. The regulation requires individual property owners to maintain sewer service from the street main to the property and to prevent unnecessary overburdening of the sewer system. Village has the legal authority to require homeowners to comply with the regulation. 2.7.1.3. The Village is committed to enforcing their ordinance to ensure that clear water is not entering the system.

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SECTION 2 MANAGEMENT PLAN2.7.2. Fats, oil and grease coat, congeal, and accumulate in pipes, leading to costly and hazardous flow of grease into laterals, sewers, entering the collection system can accumulate on sewer pipe walls causing blockages and foul odors in the sewer system. Fat, oil and grease in the sewers is typically from improper management of grease traps in food establishments such as restaurants, schools, and coffee shops. 2.7.2.1. To prevent blockages in the sewer, the Village performs maintenance cleaning on a regular basis for areas that discharge wastewater from food preparation places. 2.7.2.2. The Village continues the inspection of grease traps in food preparation places to ensure that grease is not discharged to the sewers. 2.7.2.3. Grease traps or separators must be properly maintained and cleaned on a regular basis to properly remove grease. The food establishment needs to document the maintenance and cleaning. 2.7.3. The Village also complies with the following: District rules and regulations The State plumbing code - Wisconsin Administration Code chapter COMM. 82. DNR requirements including Whitefish Bay WPDES Permit

2.8. Fiscal programs The Village currently charges a sewer fee based on water consumption and has consistently raised the sewer rates to fund the operation and maintenance and capital improvements in the collection system. This rate is reviewed annually. The Village also uses the following factors to review rates: O&M Programs - see Section 3. Condition Assessment Programs - see Section 6. Recommendations to reduce I/I. Capital Projects

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SECTION 2 MANAGEMENT PLAN2.9. Data Management 2.9.1. The Village currently uses paper forms to track all maintenance activities including inspection, cleaning, rehabilitation and replacement projects. An example of the forms used can be found in Appendix E. The Village reviews and updates these forms on a regular basis. 2.9.2. The Village uses electronic maps to track maintenance activities including future schedules. 2.10. Standard Design, Construction, and Inspection 2.10.1. The Village uses a consultant for sewer designs. Standard specification for sewer and water construction in Wisconsin, latest edition is used. 2.11. Training and Education 2.11.1. Safety. The Village uses a consultant to provide safety training on a regular basis. 2.11.2. Equipment and Tools. The Village uses vendors and equipment manufactures for training. 2.11.3. Professional Training. The Village budgets for employees to attend local training for collection system skills. 2.12. Performance Measurements 2.12.1. The Village has various performance measures that are monitored on a regular basis. These measurements are found in Table 2-4 and in Table G-1. 2.12.2. These performance measures are based on the following: The Stipulation District Rules DNR Requirements Village Goals

2.12.3. An annual review of the performance measures will be done to compare actual versus planned. See Section 8 Audit Plan for more details.

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SECTION 2 MANAGEMENT PLAN

Table 2-4 Village of Whitefish Bay Performance Measures DESCRIPTIONSEWERS Total Sewer Length in Feet Sewers cleaned (Feet/year ft/yr) Sewers inspected MANHOLES (MH) Number of Manholes in System Manholes inspected 204,336 feet 20% 20% 40,870 34,737 ft/yr ft/yr

GOALS**

906 Manholes 20% 181 MH/yr

REHABILITATION/REPLACEMENT DESCRIPTION Numbers of manholes repaired Number of manholes replaced Sewer Rehabilitated (Lined, Grout, Point Repair) Sewer Replaced MAINTENANCE ACTIVITIES Root Removal Smoke Testing Dye Water Flooding Flow Monitoring percent of the collection system TRAINING Compliance with Wisconsin Administrative Code Comm 32 STIPULATION Compliance with the Stipulation REPORTING Reporting requirements per Section 8 Number of basement backups from Village sewers Number of basement backups from Private property laterals Total number of backups Number of Sanitary Sewer Overflows **See Recommended Annual Performance Measures in Appendix G Note 1 The Village of Whitefish Bay agree[s] that they will encourage and support MMSDs continuing development, implementation, and management of flow monitoring and rain gauge systems and peak flow performance standards." The Village "retains all legal rights to object to and appeal any rules and standards implementing such MMSD activities.

TBD TBD TBD TBD

MH MH feet feet

TBD TBD TBD TBD

feet % % %

0 0 0 0

lt h

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SECTION 2 MANAGEMENT PLANTable 2-5 CMOM Program Goals, Objectives, Regulatory Expectations and Performance Measures Program Goals 1. Comply with the WPDES permit concerning sanitary sewer overflows Objectives Ensure procedures are in place to identify SSOs, report SSOs to the WDNR, and mitigate impacts from the SSOs per the WPDES permit. Ensure procedures are in place including O&M practices to minimize overflows Regulatory Expectations Untreated wastewater discharges from the system are a violation of the WPDES permit. Performance Measures (PMs) Number of Sanitary Sewer Overflows

2. Minimize the occurrence of problematic overflows

The WDNR General Permit for SSOs provides specific circumstances under which the WDNR may not take enforcement action against the discharger. These circumstances include situations where the SSO occurred to prevent loss of life, personal injury, or severe property damage.

Inspect sewers and manholes Rehabilitate or replace sewers and manholes Perform maintenance activities

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SECTION 2 MANAGEMENT PLANTable 2-5 CMOM Program Goals, Objectives, Regulatory Expectations and Performance Measures Program Goals 3. Maintain assets cost effectively Objectives Ensure preventive maintenance is performed (pump stations, manholes, and sewer pipes) Continue to conduct condition assessments on sewer assets. 4. Provide first class customer service Ensure Customer Service program is meeting the Village needs Confirm the existence of any system components that do not function according to established reliability standards. Number of customer complaints Regulatory Expectations Performance Measures (PMs)

State statutes require Inspect sewers and manholes wastewater rates to include a component for equipment Rehabilitate sewers and manholes replacement.

5. Improve or maintain system reliability

Inspect sewers and manholes Rehabilitate sewers and manholes Perform maintenance activities

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SECTION 2 MANAGEMENT PLANTable 2-5 CMOM Program Goals, Objectives, Regulatory Expectations and Performance Measures Program Goals 6. Reduce the potential threat to human health from sewer overflows Objectives Identify potential overflows Confirm the existence of locations where system overflows could pose a threat to human health. If such locations exist, develop response measures and investigate alternatives for eliminating the potential threat. The State would require a System Evaluation/Capacity Assurance Plan for the Village if the evidence shows that the system does not possess the capacity to convey peak flows . Perform flow monitoring as necessary Rehabilitate and replace sewers and manholes Regulatory Expectations Overflows from the system are a violation of the WPDES permit, Clean Water Act, and Wisconsin State law. Performance Measures (PMs) Reporting PMs Inspect, replace and rehabilitate sewers and manholes

7. Provide adequate Gain an understanding capacity to convey peak flow of the current systems ability to convey peak flows and what steps are necessary to address system inadequacies.

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SECTION 2 MANAGEMENT PLANTable 2-5 CMOM Program Goals, Objectives, Regulatory Expectations and Performance Measures Program Goals 8. Manage infiltration and inflow Objectives Reduce I/I Understand the current level of I/I in the system, the extent to which it poses a threat to the regional or municipal system operation, sources of I/I, and potential remedial measures. Establish a program to reduce I/I in situations where I/I results in service problems, overflows and building sewer backups. Such performance standards may include those that would prevent I/I from increasing in the future. Compliance with WI Administrative Code Comm 32 Regulatory Expectations If the State or MMSD determines a SECAP is required of the Village, a component of this plan will include I/I evaluation and reduction. Performance Measures (PMs) Inspect sewers and manholes Rehabilitate sewers and manholes Perform maintenance activities

9. Protect collection system worker health and safety

Provide a safe working environment for all employees.

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SECTION 2 MANAGEMENT PLANTable 2-5 CMOM Program Goals, Objectives, Regulatory Expectations and Performance Measures Program Goals 10. Operate a continuous CMOM Program Objectives Establish procedures for monitoring CMOM Program implementation and initiating program modifications. Regulatory Expectations Performance Measures (PMs) Update Plan Yearly Report per Table 8-1

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SECTION 3 OPERATION AND MAINTENANCE PLANS3.1 Background and Information

Operation and Maintenance (O&M) Programs for the collection system is critical to properly operate and maintain the collection system and to provide recommendations for future rehabilitation and replacement projects. The Village has historically inspected and cleaned sewers and manholes on a routine basis. These inspection programs are necessary to determine structural integrity, root problems, illegal connections, and I/I problems. In addition, several other programs are used on an as-needed basis to maintain the system. The Village has the following O&M Programs: 1. 2. 3. 4. 5. 6. 7. 8. 9. 3.2 Inspection of Sewers Inspection of Manholes Inspection of Easements Inspection of Critical Structures Code Compliance Sewer Cleaning Smoke Testing Dye Water Flooding Root Control Inspection - Sewers 3.2.1 The sewer inspection cycle will be performed initially on a five year cycle. Annually sewers are identified to be inspected. Based on the results of these inspections, the inspection cycle may be revised and future inspections could result in some areas inspected more frequently or less frequently than other areas. Sewer inspections will be done by using a closed circuit television camera (CCTV). All sewer inspections are documented a copy of the form used can be found in Appendix E. Sewer inspections will be used for to assess the condition of the sewer. See Section 6 for details. Based on the rating of the assessment, a recommendation shall be made for future inspection and cleaning schedules and for repairs, rehabilitation or replacement for the collection system.

3.2.2 3.2.3

3.2.4

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SECTION 3 OPERATION AND MAINTENANCE PLANS3.3 Inspection - Manholes 3.3.1 The Village of Whitefish Bay inspects manholes on a regular basis. Per the Stipulation, manholes are required to be inspected once every five years or 20 percent per year. Manhole inspections shall be documented a copy of the form used can be found in Appendix E. Manhole inspections will be used for to assess the condition of the manhole. All defects shall be replaced within 18 months in accordance with the Stipulation. Manholes were inspected previously to determine if there was any ponding on manholes. This was required per Section 20 of the Stipulation. All defects were corrected. . Based on the condition assessment rating, recommendations shall be made for future inspections, rehabilitation or replacement. See Section 6 for Condition Assessment information.

3.3.2

3.3.3

3.3.4

3.3.5

3.4

Inspection of Easements 3.4.1 The Village currently sewers located on easements or private property. It is important to keep these areas clear to ensure that access to all manholes is available for maintenance activities and emergencies. The Village has a map showing these easements in Appendix G. There is an on-going inspection program to ensure sewers and manholes are accessible.

3.5

Inspection of Critical Structures 3.5.1 The Village also performs other inspections for critical structures in the system as necessary. These can and will vary upon the situation. Critical structures are identified in Section 2.5.7 and Table 2-3.

3.6

Code Compliance 3.6.1 Properties are inspected for compliance with the ordinances and codes. The Village is committed to enforcing the ordinances and codes.

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SECTION 3 OPERATION AND MAINTENANCE PLANS3.7 Sewer Cleaning Program 3.7.1 The Village has a sewer cleaning program to remove debris from the sewers and to prevent blockages and potential sewer backups or SSOs. A copy of the form can be found in Appendix E. The sewer cleaning cycle will be performed initially on a five year cycle. Annually sewers are identified to be cleaned. Based on the results of the cleaning and inspecting the sewers, the cleaning cycle may be revised. Future inspections could result in some areas cleaned more frequently or less frequently than other areas. Other areas that may require more frequent cleaning are included in the cleaning schedule. These locations may change based on projects completed in the Village. These locations are shown on the Sewer Map G-2 Critical Locations in the Village.

3.7.2

3.7.3

3.8

Smoke Testing Program 3.8.1 Smoke testing is another element that the Village uses to identify sources of I/I and potential defects. On a regular basis, this will be reviewed to determine if smoke testing is recommended. Smoke Testing Procedure 3.8.3.1 Notify the Police and Fire Department when performing smoke testing. 3.8.3.2 This testing is not to be performed when the ground is frozen and it prevents the smoke from penetrating the soil and identifying leaks. 3.8.3.3 Typically smoke testing will be contracted out due to the resources and equipment necessary to successfully perform this task.

3.8.2

3.8.3

3.9

Dye Water Flooding 3.9.1 Dye Water Flooding is another element that the Village uses to identify sources of I/I. Dye Water will be used on an as-needed basis. Dye Water Flooding Guidelines:

3.9.2 3.9.3

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SECTION 3 OPERATION AND MAINTENANCE PLANS3.9.3.4 Notify the Police and DNR prior to doing dye water flooding to let them know that the water will be colored in the event that it reaches navigable waters. 3.9.3.5 This testing should not to be performed when the ground is frozen and it prevents the water from penetrating the soil and identifying leak 3.9.3.6 Typically dye water flooding will be contracted out due to the resources and equipment necessary to successfully perform this task. 3.10 Root Control 3.10.1 Root intrusion in collection systems is another source of blockages and overflows. Control of roots will be done in combination with routine cleaning to reduce blockages and overflow. 3.10.2 Root Control is scheduled with the cleaning. See Appendix G for Root Cutting Map.

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SECTION 4 CAPACITY PLAN4.1 Background and Information

The Village is required to have sufficient capacity during dry weather events and to manage peak wet weather flows. This includes identifying areas during wet weather events where excess flow from I/I occurs. The Village is land-locked and fully developed. There is minimal or no redevelopment. Future flows are anticipated to remain the same. 4.2 Capacity 4.2.1 4.2.2 Dry Weather Conditions. The Village has no dry weather capacity restrictions. Wet Weather Conditions. The Village will continue to reviews flows during wet weather events to reduce I/I. Problems during wet weather events and SSOs are analyzed to determine the root cause of these problems. A root cause failure analysis form is included in Appendix E. The Village has an on-going inspection program to identify I/I. The Village is enforcing their ordinances on a continuous basis to ensure that I/I is reduced.

4.2.3 4.2.4

4.3

Capital Improvements 4.3.1 The Village has a five year capital improvements plan (CIP). Projects have been identified from the O&M Programs defined in Section 3. The Plan includes projects to reduce peak wet weather flows.

4.3.2

4.4

Field Investigation 4.4.1 The Village performs field investigations on a regular basis to identify I/I, defects and other potential problems. All problems are based on: customer service requests; staff recommendations; or as needed. Problem areas and overflows are investigated. Overflows are reported See Section 5 Overflow Response Plan and Appendix D for more details. Observations and recommendations from these field investigations are used to enhance the O&M programs and to provide repair, rehabilitation and replacement recommendations.

4.4.2

4.4.3

4.5

Flow Modeling 4.5.1 The Village currently does not use flow modeling to evaluate the collection system.t h

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SECTION 4 CAPACITY PLAN4.5.2 Flow modeling may be considered if the Village determines that it is necessary to manage peak wet weather flows.

4.6

Flow Monitoring 4.6.1 The Village will use the District flow monitors to evaluate flows in the system and to evaluate capacity constraints. Additional flow monitoring may be done on a case-by-case basis to identify high I/I areas and to confirm flows in the system.

4.6.2

4.7

I/I Reduction 4.7.1 4.7.2 The Village continues to address I/I reduction on a regular basis . Village properties were mostly constructed with building foundations connected to the sanitary sewer or combined sewer. Current plumbing code requirements require building foundations to be connected to a sump pump or storm sewer, however existing properties were not required to update the plumbing to current standards. Rehabilitation and replacement programs are based on reducing I/I in addition to ensuring that the structural integrity of the assets is maintained. Projects are included in the Village CIP for planning and financing purposes.

4.7.3

4.7.4 4.8

Peak Flow Performance Standards Pursuant to the Stipulation between the State of Wisconsin and the Satellite Municipalities, the Village agree[s] that [it] will encourage and support MMSDs continuing development, implementation, and management of flow monitoring and rain gauge systems and peak flow performance standards. The Village retains all legal rights to object to and appeal any rules and standards implementing such MMSD Activities. Refer to Table 2-5 and Appendix G-1 for additional information.

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SECTION 5 OVERFLOW RESPONSE PLAN5.1 Background and Information

An Overflow Response Plan (ORP) is necessary to protect public health and the environment. It provides procedures to respond to overflows, documents work and reports notification to the appropriate parties. The ORP is a standard operating procedure (SOP) and the SOP is included in Appendix D. A summary of the Plan is included in this section. 5.2 Procedure 5.2.1 The Village has an ORP that is updated on a regular basis and is included in Appendix D- Overflow Response Plan. This includes: Procedures to respond to SSOs Minimize the effects of the SSO Provide containment and proper clean-up of the SSO Investigate SSOs Notify stake-holders of a SSO. 5.2.2 Root Cause Failure Analysis. All SSOs are required to be investigated to determine the root cause of the overflow. A Root Cause Failure Analysis Form can be found in the ORP SOP (Appendix D) and in Appendix E..

5.3

Overflow Structures and Monitored Sites 5.3.1 There are fourteen gravity sewer overflow points in the Village system as identified in Table 2-3 Sanitary Sewer Overflow and Monitored Sites. There are two sites that are monitored for potential basement backups as identified in Table 2-3. As part of the implementation of the CMOM Plan, an Standard Operating Procedure (SOP) was developed to address these overflow points. See Wet Weather SOP in Appendix F. In the event of an overflow or an emergency (blocked sewer, collapse, backup, etc.) SOPs should be followed.

5.3.2

5.3.3

5.3.4

5.4

Notification

In the event of an overflow, the Village needs to submit notification to various stakeholders. See emergency contact list in the Appendix D, Table D-2. These are as follows:

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SECTION 5 OVERFLOW RESPONSE PLAN1. Notify Village Manager 2. Verbal or email notification to the DNR within 24 hours notification that an overflow occurred 3. Written overflow report to the DNR within five (5) days. The form can be found on the DNR website and is included in the Appendix E. 4. Email to the Water Supply Utilities that are impacted by the overflow. These notifications are found in the ORP. 5.5 Weather Forecast

The Village also uses weather forecast to predict wet weather events and melting snow events which can assist in predicating high flows in the system and allows Village staff to be prepared to address potential problems in the collection system. 5.6 Channel 4 NBC - TMJ 4 news station http://weather.todaystmj4.com/ Channel 6 FOX - www.fox6now.com Channel 12 ABC www.wisn.com http://www.wunderground.com/cgi-bin/findweather/getForecast/ www.noaa.gov www.nws.noaa.gov www.weather.com District http://v3.mmsd.com/StormUpdate.aspx/

Root Cause Failure Analysis 5.6.1 5.6.2 All overflows are investigated to determine what caused the overflow. Other problems in the system, such as blockages or basement backups, are also investigated to determine the cause. See Root Cause Analysis Form in Appendix E.

5.6.3 5.7

References 5.7.1 5.7.2 5.7.3 See Overflow Response Plan SOP in Appendix D for more details. Wet Weather SOP in Appendix F Root Cause Failure Analysis Form in Appendix E

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SECTION 6 CONDITION ASSESSMENT PROGRAM6.1 Background and Information

A Condition Assessment Program involves documentation and inspection of the collection system to assess the condition of the infrastructure. The information gathered during the assessment is used to plan and budget for repair, rehabilitation and replacement of the assets. Also from these assessments, recommendations for additional inspection and cleaning are made. There are several key elements that are part of the Condition Assessment Program: 6.2 Condition Assessment Key Elements 6.2.1 The tools listed in Section 3 - Operation and Maintenance Plans will be used for condition assessment. See Section 3 for more details. These tools include but are not limited to inspection, cleaning, smoke testing, dye water flooding and root control. 6.2.2 Document inspections from sewers and manholes. 6.2.3 Document cleaning results. 6.2.4 Data from the inspections and cleaning is reviewed and evaluated by an experienced person. The condition of the sewers and manholes is assessed and rated via the assessment code. The assessment code used is the Pipeline Assessment and Certification Program (PACP) as provided through the National Association of Sewer Service Companies (NASSCO). Sewer inspections are performed by a consultant. 6.2.5 Based on the condition assessment rating, recommendations are made on an ongoing basis to repair, rehabilitate, and replace to properly maintain the asset 6.2.6 Analysis of system performance, maintenance history, age materials and structural risk analysis is also used to help prioritize recommendations. 6.3 Condition Assessment Recommendations 6.3.1 Recommendations to repair, replace, and rehabilitate the assets are based on the results of the condition assessment. 6.3.2 Depending upon the severity of the condition, the recommendations shall be performed by staff or contracted out to a consulting firm. 6.3.3 Solutions for repair and rehabilitation will depend up on the condition of the asset and using the appropriate technology for the problem. 6.3.4 Recommendations will be used for O&M budgets and CIP.t h

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SECTION 7 COMMUNICATIONS

7.1

Background and Information

The Village of Whitefish Bay communicates with the DNR, District, the Village Board and their customers on a regular basis. The Village is governed by a Village President and 6 Village Trustees as outlined in the Village Organization Chart in Figure 2-1. 7.2 Methods of Communication

The Village Board meets on a monthly basis to decide administrative issues related to finance, personnel, operations, SSO reduction and elimination, sanitary sewer system improvements and other Village business is discussed. Any SSO events or other capacity issues are presented and discussed at the Board meetings. Currently, the Village has a web-site and quarterly newsletter to update their customers. 7.3 CMOM Communication

Topics of discussion related to the CMOM Plan are: 1. Financial Impact to the Village. Is the budget adequate to support initiatives including but not limited to: Capital improvements, operation and maintenance activities, personnel and equipment. 2. Problem areas in the system. 3. Sanitary Sewer Overflows. 4. Communication to stakeholders. 5. Meeting the CMOM Goals 6. Reducing I/I in the system in the most cost-effective way. 7.4 Reporting Methods

As part of the Communications Plan, the Village has reporting requirements to other entities as listed in Table 8-1 and as outlined in the Overflow Response Plan (Appendix D). In addition, an annual Communications Plan as required by the District will be submitted including the component items listed above and in the District rules. The plan will include an update on meeting the performance measures. 7.5 References 1. Table 8-1 Audit and Reporting Schedule 2. Overflow Response Plan (ORP) Appendix D.

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SECTION 8 CMOM AUDIT PLAN8.1 Background and Information

A CMOM audit is necessary to ensure that the Plan is properly implemented goals and objectives are met and performances measures are reviewed, evaluated, an updated on a regular basis. The CMOM Plan provides the framework and documentation to implement the programs that the Village is currently doing. This Plan is meant to be a working document and will be updated as needed. As part of the Audit the following will be done: 1. 2. 3. 4. 8.2 Audit and review the CMOM Plan Monitor the Plan Provide recommendations Update the CMOM Plan Audit and Review the Plan 8.2.1 Audits shall be done every five years in accordance with the Stipulation. Table 8-1 for reporting requirements. Review the Plan for the following: 8.2.2.1 Goals are applicable to the Village 8.2.2.2 Goals and strategies are applicable and meet the Stipulation, DNR and District requirements. 8.2.2.3 Program elements are applicable and relevant 8.2.2.4 Performance measures are being met. See Table 2-4 for performance measures. 8.2.2.5 Budget is adequate to meet the recommendations from the various CMOM components. 8.3 Monitor the Plan 8.3.1 Monitor the implementation and measure the effectiveness of the program through performance measures. Annually, review goals and performance measures to measure the program effectiveness.t h

See

8.2.2

8.3.2

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SECTION 8 CMOM AUDIT PLAN8.3.3 8.4 Submit reports as required by DNR and the District.

Provide Recommendations 8.4.1 8.4.2 Provide recommendations to revise the performance measures. Provide recommendation to update the Plan.

8.5

Update the CMOM Plan 8.5.1 Update the CMOM Plan based on the audit, feedback from employees and recommendations. See Tables 8-2 and 8-3 to update the CMOM Plan and Table 8-4 for the CMOM Plan Distribution List.

EXHIBIT 8-1 AUDIT & REPORTING SCHEDULE DESCRIPTIONAUDIT

2009 2010 2011 2012 2013 2014

Develop goals and performance measures Review actual goals and performance measures Review and update budget and rates CMOM AuditREPORTING SCHEDULE

X X X

X X X

X X X

X X X

X X X

X X X X

District I/I Report March 1st District Chapter 13 Storm April 30th District Communications Annual Report DNR CMAR Report June 30th WNDR NR 216 Report March 31st MS4 Permit Clean water funding reporting requirements as necessary. Sanitary Sewer Overflow Notification See Overflow Response Plan in Appendix D.

X X X X X

X X X X X

X X X X X

X X X X X

X X X X X

X X X X X

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SECTION 8 CMOM AUDIT PLANTable 8-2 CMOM Plan Update Documentation Table Update No. Ver 2 Update Manual No. 1 Update Manual No. 2 Update Manual No. 3 Update Manual No. 4 & 5 Update Manual No. 6 Comments

11/30/09 2/25/2010

11/30/09 2/25/2010

11/30/09 2/25/2010

11/30/09 2/25/2010

11/30/09 2/25/2010 Final Submitted 2/25/2010 Approved by District 4/8/2010

Ver 3

February 25th, 2010

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SECTION 8 CMOM AUDIT PLAN

Table 8-3 Audit and Plan Update Documentation Table Audit Completed By: Audit Date: CMOM Plan Updated By: Plan Updated Date Approved By: Date Approved Update Number 1

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SECTION 8 CMOM AUDIT PLAN

TABLE 8-4 CMOM PLAN DISTRIBUTION LIST MANUAL NO. No. 1 No. 2 No. 3 & 4 NAME ENTITY DATE

Daniel Naze Aaron Jahncke Debra Jensen

Village of Whitefish Bay Village of Whitefish Bay District 260 West Seeboth, Milwaukee WI, 53204 Superior Engineering, S75W13139 Oxford Court, Muskego, WI 53150

6/29/2009 6/29/2009 6/29/2009

No. 5

Joan B. Hawley

6/29/2009

February 25, 2010

Page 33

Appendix A

Appendix B

MMSD CMOM Program

Appendix 1-1

Stipulation Requirements of the Districts CMOM ProgramBelow is the portion of the text (from pages 7, 8, and 9) of the Stipulation entered into between the Milwaukee Metropolitan Sewerage District and the State of Wisconsin in 2002 that describes the District CMOM Program requirements. CAPACITY, MANAGEMENT, OPERATION AND MAINTENANCE (CMOM) PROGRAM 6. Combined sewer overflows and sanitary sewer overflows present important concerns for public health and the environment. The State, through the Department of Natural Resources, acknowledges that the District has accomplished significant reductions in the number of overflows experienced with the Districts Metropolitan Interceptor Sewer System through implementation of the Water Pollution Abatement Program (WPAP.) 7. While sanitary sewer overflows in the Districts system have been significantly reduced, there are still sanitary sewer overflows within the Districts and its satellite municipalities sanitary sewer systems. To continue the Districts program to reduce with the goal of eliminating all non-permitted sanitary sewer overflows, the District shall implement the regional Capacity, Management, Operation and Maintenance (CMOM) program. The regional CMOM shall be comprised of four integrated components: A. Management Plan. A plan that outlines the goals of the CMOM, the organizational structure to manage it, the legal authority to control infiltration and inflow (I/I), design criteria, benchmarking data, and performance measures to attain the goals. A significant effort associated with the Management Plan shall be the development of an asset management (AM) program that provides for both programmed maintenance and tracking of the asset condition to enable early recognition of expansions or major rehabilitation necessary to avoid capacity limitations. B. Overflow Response Plan. An overflow response plan that identifies measures to protect public health and the environment. This plan will outline the public notification, permit reporting, measuring and monitoring steps to be taken during an overflow event. C. System Evaluation and Capacity Assurance Plan. A Plan for system evaluation and capacity assurance for peak flow conditions. This plan shall identify necessary capital improvements to meet the projected flows and an implementation plan that describes timing and responsibilities for implementing each capital project. D. Communication and Program Audit Plan. On a regular basis the District shall report to the Department on the implementation and performance of the CMOM program. The communication and program audit plan shall allow for public input during the development and implementation of the CMOM. E. The approach to be used by the District to initiate and maintain the CMOM program shall include the following steps: 1) Retention of a consultant by no later than December 31, 2002, to provide program oversight and guidance. 2) Review of existing operations and existing management and capital improvement plans. 3) Development of an action plan to assess the required changes to existing plans and to develop a critical plan approach to a CMOM programPage 1 of 2 June 2007

MMSD CMOM Program

Appendix 1-1

Stipulation Requirements of the Districts CMOM Program4) Concurrent with previous steps, review of existing information on asset management, including field verification as required, and software development to provide a simplified data base to manage the capital assets of the District. 5) Open and maintain a CMOM dialog with the 28 satellite municipalities through the Technical Advisory Team with the goal of assisting the satellite municipalities with developing individual CMOM programs. The District shall develop prospective measures for the satellite systems that will reflect the requirements of the Districts CMOM program. 6) This entire CMOM initiative will be coordinated with the ongoing facilities planning and shall be completed by no later than June 30, 2007 and documented in the 2020 Facilities Plan to ensure future oversight of this program.

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MMSD CMOM Program

Appendix 1-2

Withdrawn SSO RuleBelow is the draft SSO Rule language (USEPA proposed rule 122.42 paragraphs (e), (f), and (g)) that was proposed in 2001 and subsequently withdrawn. (e) Municipal Sanitary Sewer System Capacity, Management, Operation and Maintenance Programs. (1) General Standards. You, the permittee, must: (i) Properly manage, operate, and maintain, at all times, all parts of the collection system that you own or over which you have operational control; (ii) Provide adequate capacity to convey base flows and peak flows for all parts of the collection system you own or over which you have operational control; Take all feasible steps to stop, and mitigate the impact of, sanitary sewer overflows in portions of the collection system you own or over which you have operational control; Provide notification to parties with a reasonable potential for exposure to pollutants associated with the overflow event; and Develop a written summary of your CMOM Program and make it, and the audit under paragraph (e) (2) (ix) of this section, available to any member of the public upon request.

(iii)

(iv) (v)

(2)

Components of CMOM Program. You must develop and implement a capacity, management, operation and maintenance (CMOM) program to comply with paragraph (e)(1) of this section. If you believe that any element of this section is not appropriate or applicable for your CMOM program, you program does not need to address it, but your written summary must explain why that element is not applicable. The Director will consider the quality of the CMOM program, its implementation and effectiveness in any relevant enforcement action, including but not limited to any enforcement action for violation of the prohibition of any municipal sanitary sewer system discharges described at paragraph (f) of this section. The program must include the following components, with the exception of non-applicable components as discussed above: (i) (ii) Goals. You must specifically identify the major goals of your CMOM program, consistent with the general standards identified above. Organization. You must identify: (A) Administrative and maintenance positions responsible for implementing measures in your CMOM program, including lines of authority by organization chart or similar document; and (B) The chain of communication for reporting SSOs under paragraph (g) of this section from receipt of a complaint or other information to the person responsible for reporting (iii) Legal Authority. You must include legal authority, through sewer use ordinances, service agreements or other legally binding documents, to: (A) Control infiltration and connections from inflow sources;Page 1 of 7 June 2007

MMSD CMOM Program

Appendix 1-2

Withdrawn SSO Rule(B) Require that sewers and connections be properly designed and constructed; (C) Ensure proper installation, testing, and inspection of new and rehabilitated sewers (such as new or rehabilitated collector sewers and new or rehabilitated service laterals); (D) Address flows from municipal satellite collection system; and (E) Implement the general and specific prohibitions of the national pretreatment program that you are subject to under 40 CFR 403.5. (iv) Measures and Activities. Your CMOM program must address the following elements that are appropriate and applicable to your system and identify the person or position in your organization responsible for each element: (A) Provide adequate maintenance facilities and equipment; (B) Maintenance of a map of the collection system; (C) Management of information and use of timely, relevant information to establish and prioritize appropriate CMOM activities (such as the immediate elimination of dry weather overflows or overflows into sensitive waters such as public drinking water supplies and their source waters, swimming beaches and waters where swimming occurs, shellfish beds, designated Outstanding National Resource Waters, National Marine Sanctuaries, waters within Federal, State, or local parks, and water containing threatened or endangered species or their habitat), and identify and illustrate trends in overflows, such as frequency and volume; (D) Routine preventive operation and maintenance activities; (E) A program to assess the current capacity of the collection system and treatment facilities which you own or over which you have operational control; (F) Identification and prioritization of structural deficiencies and identification and implementation of short-term and long-term rehabilitation actions to address each deficiency; (G) Appropriate training on a regular basis; and (H) Equipment and replacement parts inventories including identification of critical replacement parts. Design and Performance Provisions. You must establish: (A) Requirements and standards for the installation of new sewers, pumps and other appurtenances; and rehabilitation and repair projects; and (B) Procedures and specifications for inspecting and testing the installation of new sewers, pumps and other appurtenances and for rehabilitation and repair projects. Monitoring, Measurement, and Program Modifications. You must: (A) Monitor the implementation and, where appropriate, measure the effectiveness of each element of your CMOM program; andPage 2 of 7 June 2007

(v)

(vi)

MMSD CMOM Program

Appendix 1-2

Withdrawn SSO Rule(B) Update program elements as appropriate based on monitoring or performance evaluations; and (C) Modify the summary of your CMOM program as appropriate to keep it updated and accurate. (vii) Overflow Emergency Response Plan. You must develop and implement an overflow emergency response plan that identifies measures to protect public health and the environment. The plan must include mechanisms to: (A) Ensure that you are made aware of all overflows, to the greatest extent possible; (B) Ensure that overflows (including those that do not discharge to waters of the U.S.) are appropriately responded to, including ensuring that reports of overflows are immediately dispatched to appropriate personnel for investigation and appropriate response; (C) Ensure appropriate immediate notification to the public, health agencies, other impacted entities (e.g. water suppliers) and the NPDES authority. The CMOM program should identify the public health and other officials who will receive immediate notification; (D) Ensure that appropriate personnel are aware of and follow the plan and are appropriately trained; and (E) Provide emergency operations. (viii) System Evaluation and Capacity Assurance Plan. You must prepare and implement a plan for system evaluation and capacity assurance if peak flow conditions are contributing to an SSO discharge or to noncompliance at a treatment plant unless you have already taken steps to correct the hydraulic deficiency or the discharge meets the criteria of paragraph (f) (2) [Discharges Caused by Severe Natural Conditions] of this section. At a minimum the plan must include: (A) Evaluation. Steps to evaluate those portions of the collection system which you own or over which you have operational control which are experiencing or contributing to an SSO discharge caused by hydraulic deficiency or to noncompliance at a treatment plant. The evaluation must provide estimates of peak flows (including flows from SSOs that escape from the system) associated with conditions similar to those causing overflow events, provide estimates of the capacity of key system components, identify hydraulic deficiencies (including components of the system with limiting capacity) and identify the major sources that contribute to the peak flows associated with overflow events. (B) Capacity Enhancement Measures. Establish short- and long-term actions to address each hydraulic deficiency including prioritization, alternatives analysis, and a schedule. (C) Plan Updates. The plan must be updated to describe any significant change in proposed actions and/or implementation schedule. The plan must also be updated to reflect available information on the performance of measures that have been implemented.

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MMSD CMOM Program

Appendix 1-2

Withdrawn SSO RuleCMOM Program Audits. As part of the NPDES permit application, you must conduct an audit, appropriate to the size of the system and the number of overflows, and submit a report of such audit, evaluating your CMOM and its compliance with this subsection, including its deficiencies and steps to respond to them. Communications. The permittee should communicate on a regular basis with interested parties on the implementation and performance of its CMOM program. The communication system should allow interested parties to provide input to the permittee as the CMOM program is developed and implemented. Small Collection Systems. The Director of the NPDES authority may make the following modifications when establishing the CMOM program permit condition for: (i) Municipal sanitary sewer collection systems with an average daily flow of 1.0 million gallons per day or less, the CMOM permit provision may omit the following paragraphs: (e) (2) (iii)(A) through (E); (e) (2) (iv) (A), and (e) (2) (iv) (C) through (H) of this section. In addition, the requirements in paragraph (e) (2) (v) of this section may be modified for municipalities that are not expected to have significant new installations of sewers, pumps and other appurtenances. (ii) Municipal sanitary sewer collection systems with an average daily flow of 2.5 million gallons per day or less, the requirement to develop a written summary of the permittees CMOM plan ((e) (1) (v)) and the requirement to conduct an audit and prepare a written audit report ((e) (2) (ix)) may be omitted unless triggered by the occurrence of an SSO that discharges to waters of the United States from the permittees collection system during the term of the permit. Municipal Sanitary Sewer Systems Prohibition of Discharges. (1) General Prohibition. Municipal sanitary sewer system discharges to waters of the United States that occur prior to a publicly owned treatment works (POTW) treatment facility are prohibited. The term POTW treatment facility means an apparatus or device designed to treat flows to comply with effluent limitations based on secondary treatment regulations or more stringent water quality-based requirements. Neither the bypass or the upset provisions at (m) and (n), respectively, apply to these discharges. Discharges Caused by Severe Natural Conditions. The Director may take enforcement action against the permittee for a prohibited municipal sanitary sewer system discharge caused by natural conditions unless the permittee demonstrates through properly signed, contemporaneous operating logs, or other relevant evidence that: (i) The discharge was caused by severe natural conditions (such as hurricanes, tornados, widespread flooding, earthquakes, tsunamis, and other similar natural conditions); (ii) There were no feasible alternatives to the discharge, such as the use of auxiliary treatment facilities, retention of untreated wastewater, reduction of inflow and infiltration, use of adequate backup equipment, or anPage 4 of 7 June 2007

(ix)

(3)

(4)

(f)

(2)

MMSD CMOM Program

Appendix 1-2

Withdrawn SSO Ruleincrease in the capacity of the system. This provision is not satisfied if, in the exercise of reasonable engineering judgment, the permittee should have installed auxiliary or additional collection system components, wastewater retention or treatment facilities, adequate back-up equipment or should have reduced inflow and infiltration; and (iii) The permittee submitted a claim to the Director within 10 days of the date of the discharge that the discharge meets the conditions of this provision. Discharges Caused by Other Factors. For discharges prohibited by paragraph (f) (1) of this section, other than those covered under paragraph (f) (2) of this section, the permittee may establish an affirmative defense to an action brought for noncompliance with technology based permit effluent limitations if the permittee demonstrates through properly signed, contemporaneous operating logs, or other relevant evidence that: (i) The permittee can identify the cause of the discharge event; (ii) The discharge was exceptional, unintentional, temporary and caused by factors beyond the reasonable control of the permittee; (iii) The discharge could not have been prevented by the exercise of reasonable control, such as proper management, operation and maintenance; adequate treatment facilities or collection system facilities or components (e.g., adequately enlarging treatment or collection facilities to accommodate growth or adequately controlling and preventing infiltration and inflow); preventive maintenance; or installation of adequate backup equipment; (iv) The permittee submitted a claim to the Director within 10 days of the date of the discharge that the discharge meets the conditions of this provision; and (v) The permittee took all reasonable steps to stop, and mitigate the impact of, the discharge as soon as possible. Burden of proof. In any enforcement proceeding, the permittee has the burden of proof to establish that the criteria in this section have been met. Municipal Sanitary Sewer Systems Reporting, Public Notification and Recordkeeping. This condition establishes recordkeeping, reporting and public notification requirements for your municipal sanitary sewer system and sanitary sewer overflows from your municipal sanitary sewer system. You do not have to report sanitary sewer overflows under 122.41 (l) if the sanitary sewer overflows are reported under this section. (1) Definition of Sanitary Sewer Overflow. A sanitary sewer overflow (SSO) is an overflow, spill, release, or diversion of wastewater from a sanitary sewer system. SSOs do not include combined sewer overflows (CSOs) or other discharges from the combined portions of a combined sewer system. SSOs include: (i) Overflows or releases of wastewater that reach waters of the United States; (ii) Overflows or releases of wastewater that do not reach waters of the United States; and (iii) Wastewater backups into buildings that are caused by blockages or flow conditions in a sanitary sewer other than a building lateral. WastewaterPage 5 of 7 June 2007

(3)

(4)

(g)

MMSD CMOM Program

Appendix 1-2

Withdrawn SSO Rulebackups into buildings caused by a blockage or other malfunction of a building lateral that is privately owned is not an SSO. Immediate Notifications and Follow-Up Reports. You must provide the following additional reports for sanitary sewer overflows (including overflows that do not reach waters of the United States) that may imminently and substantially endanger human health: (i) You must immediately notify the public, health agencies and other affected entities (e.g. public water systems) of overflows that may imminently and substantially endanger human health. The notification should be in accordance with your CMOM overflow emergency response plan (see paragraph (e) (2) (vii) of this section); (ii) You must provide to the NPDES authority either an oral or electronic report as soon as practicable within 24 hours of the time you become aware of the overflow. The report must identify the location, estimated volume and receiving water, if any, of the overflow; and (iii) You must provide to the NPDES authority within 5 days of the time you become aware of the overflow a written report that contains: (A) The location of the overflow; (B) The receiving water (if there is one); (C) An estimate of the volume of the overflow; (D) A description of the sewer system component from which the release occurred (e.g., manhole, constructed overflow pipe, crack in pipe); (E) The estimated date and time when the overflow began and stopped or will be stopped; (F) The cause or suspected cause of the overflow; (G) Steps taken or planned to reduce, eliminate, and prevent reoccurrence of the overflow and a schedule of major milestones for those steps; and (H) Steps taken or planned to mitigate the impact(s) of the overflow and a schedule of major milestones for those steps. (iv) The Director may waive the written report required by paragraph (g) (2) (iii) of this section 122.42 (g) (2) (iii) on a case-by-case basis. Discharge Monitoring Reports. You must report sanitary sewer overflows that discharge to waters of the United States on the discharge monitoring report (DMR), including the following information: (i) The total number of system overflows that discharge to waters of the United States that occurred during the reporting period; (ii) The number of locations at which sanitary sewer overflows that discharge to waters of the United States occurred during the reporting period that resulted from flows exceeding the capacity of the collection system; (iii) The number of sanitary sewer overflows that discharge to waters of the United States that are unrelated to the capacity of the collection system that occurred during the reporting period; and (iv) The number of locations at which sanitary sewer overflows that discharge to waters of the United States that occurred during the reporting period that are unrelated to the capacity of the collection system.Page 6 of 7 June 2007

(2)

(3)

MMSD CMOM Program

Appendix 1-2

Withdrawn SSO Rule(4) Annual Report. (i) You must prepare an annual report of all overflows in the sewer system, including overflows that do not discharge to waters of the United States. The annual report must include the date, the location of the overflow, any potentially affected receiving water, and the estimated volume of the overflow. The annual report may summarize information regarding overflows of less than approximately 1,000 gallons. You must provide the report to the Director and provide adequate notice to the public of the availability of the report. (ii) System serving fewer than 10,000 people are not required to prepare an annual report if all DMRs for the preceding 12 months show no discharge to waters of the United States from overflows. Recordkeeping. You, the permittee, must maintain a record of the following information for a period of at least 3 years from the date of the overflow or other recorded event: (i) For each sanitary sewer overflow, including overflows that did not discharge to waters of the United States, which occurred in your collection system or as a result of conditions in a portion of the collection system which you own or over which you have operational control: (A) The location of the overflow and the receiving water if any; (B) An estimate of the volume of the overflow; (C) A description of the sewer system component from which the release occurred (e.g., manhole, constructed overflow pipe, crack in pipe); (D) The estimated date and time when the overflow began and when it stopped; (E) The cause or suspected cause of the overflow; and (F) Steps that have been and will be taken to prevent the overflow from recurring and a schedule for those steps. (ii) Work orders which are associated with investigation of system problems related to sanitary sewer overflows; (iii) A list and description of complaints from customers or others; and (iv) Documentation of performance and implementation measures. Additional Public Notification. You must notify the public of overflows, including overflows that do not discharge to waters of the United States, in areas where an overflow has a potential to affect human health. The criteria for notification should be developed in consultation with potentially affected entities. The notification should be in accordance with your CMOM overflow emergency response plan (see paragraph (e) (2) (vii) of this section.)

(5)

(6)

Page 7 of 7

June 2007

Appendix C

CMOM PLAN APPENDIX C District Copy Only Municipalities received a copy of the complete Strategic Plan to include in their Manuals. For purpose of this document only the cover sheet has been included.

CMOM Strategic Plan Village of Whitefish Bay 1/7/2008

FINALEXECUTIVE SUMMARY ................................................................................................................................................1 Introduction and Background .........................................................................................................................................1 CMOM Program Development Process .........................................................................................................................1 Major CMOM Program Implementation Tasks .................................................................................................................3 Chapter 1 - Strategy Introduction .......................................................................................................................................6 1.0 1.1.0. Program Background ..........................................................................................................................................6 CMOM Program Development Process .........................................................................................................8

1.2.0. Strategy Outline...................................................................................................................................................9 1.3.0 Potential Regulatory Expectations.......................................................................................................................10 1.3.1. MMSD Rules......................................................................................................................................................10 1.3.2. Satellite Stipulation Requirements .....................................................................................................................10 1.4.0. CMOM Tactics Which the Village of Whitefish Bay Is Already Practicing......................................................12 1.4.1 1.4.2 1.4.3 1.4.4 1.4.5 1.4.6 1.4.7 1.4.8 1.4.9 1.4.10 1.4.11 Organizational Structure, Including Administrative and Maintenance Positions .....................................12 Legal Authority to Control I/I and Construction Standards......................................................................12 Provide Adequate Maintenance Facilities and Information Management ................................................12 Program to Assess the Current Capacity of the Collection.......................................................................13 Identification of Structural Deficiencies and Implementation of Rehabilitation Actions .........................13 Design Requirements and Standards for the Installation of New Sewers.................................................13 Monitor, Measure and Update Program Elements as Appropriate ...........................................................13 Provide a Detailed SSO Emergency Response Plan .................................................................................14 Provide for Public Notification of SSO Occurrences ...............................................................................14 Provide a System Evaluation and Capacity Assurance Plan to Address SSOs.........................................14 Conduct a CMOM Program Audit as Part of the Permit Application ......................................................14

Chapter 2 - Management Plan Strategy ............................................................................................................................15 2.1.0. 2.1.1. 2.1.2. 2.1.3. CMOM Program...........................................................................................................................................15 CMOM Program Mission Statement ............................................................................................................16 CMOM Program Goals ................................................................................................................................16 CMOM Program Objectives.........................................................................................................................17

Chapter 3 - Overflow Response Plan Strategy .................................................................................................................25 Chapter 4 - System Evaluation and Capacity Assurance Plan Strategy ...........................................................................40 Chapter 5 - CMOM Program Communication Plan Strategy ...........................................................................................54 Chapter 6 CMOM Program Audit Plan Strategy...........................................................................................................57 Chapter 7 - CMOM Program Implementation Strategy ...................................................................................................60 7.1.0 Page i Summary of Implementation Activities........................................................................................................61

CMOM Strategic Plan Village of Whitefish Bay 1/7/2008

FINAL7.2.0. Documents to Be Prepared As Part of CMOM Program Implementation ....................................................62

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EXECUTIVE SUMMARY Introduction and Background In May 2002, the Milwaukee Metropolitan Sewerage District (MMSD) entered into a Stipulation (MMSD Stipulation) with the Wisconsin Department of Natural Resources (WDNR). Among other items, the Stipulation requires MMSD to implement a Capacity assurance, Management, Operations and Maintenance (CMOM) Program. The MMSD Stipulation also required MMSD to amend its rules to by June 30, 2007 to require CMOM Programs for all MMSD satellite municipalities. In December 2005, the Village of Whitefish Bay, along with other MMSD satellites, entered into a Stipulation with the WDNR (Satellite Stipulation), that committed the Village to develop and implement a CMOM Program. The CMOM concept is set forth in a U. S. Environmental Protection Agency (USEPA) draft rule that addresses sanitary sewer overflow (SSO) control. A provision of the draft document is a requirement for a comprehensive collection system program that includes four key components, 1) Capacity assurance, 2) Management, 3) Operation, and 4) Maintenance; hence the acronym CMOM. The goal of CMOM is to clearly define proper operation and maintenance of the collection system and a system owners duty to mitigate SSOs. The USEPA CMOM draft would require a collection system owner to: Properly manage, operate and maintain, at all times, all parts of the collection system that it owns or over which it has operational control. Provide adequate capacity to convey base flows and peak flows for all parts of the collection system it owns or over which it has operational control. Take all feasible steps to stop, and mitigate the impact of, sanitary sewer overflows in portions of the collection system it owns or over which it has operational control. Provide notification to parties with a reasonable potential for exposure to pollutants associated with the overflow event. Develop a written summary of the CMOM program and make it, and the audit under section (e)(2)(ix), available to any member of the public upon request.

The WDNR is developing its CMOM regulations which closely follow the federal version. It is anticipated that the WDNR permit staff will have the authority to include CMOM provisions in individual Wisconsin Pollution Discharge Elimination System (WPDES) permits and the general collection system WPDES permits. Once this occurs, the Village would be required to follow WDNR CMOM permit requirements. CMOM Program Development Process The CMOM Program developed for Village followed a two step process. First, a CMOM Readiness Review of the Village was performed. Second, this CMOM Strategic Plan was developed.Page 1

CMOM Strategic Plan Village of Whitefish Bay 1/7/2008

FINAL For the CMOM Readiness Review, a consulting team led by Superior Engineering conducted a workshop with managers from the Village to familiarize them with the Readiness Review process. Afterward, the team collected information for the Readiness Review from documents, staff interviews, and field observations. The Readiness Review identified a number of required practices and documents were already in place, some areas needed to be improved to meet the CMOM Plan requirements. . After evaluating its current status in each practice area, the Village selected a goal and a priority for progressing in each area. The following list summarizes the highest priorities Village identified for developing its CMOM program: 1. Identify and reduce infiltration/inflow 2. Review and enhance the existing in-house cleaning and inspection program 3. Standardize O&M Procedures

Following the Readiness Review, the same consulting team guided Village staff through a process to develop the CMOM Strategic Plan. The first task in this process involved the Village reviewing a CMOM Program Mission Statement followed by program goals and objectives. The Village staff is developing a mission statement to guide development of the strategy which will be required to be approved by the Village Board. This will be one of the first steps in the development of the CMOM Plan.

Summary of Findings of Readiness Review The Village of Whitefish Bay has completed most of the tasks that are required to comply with a CMOM Plan. To complete the CMOM Plan, the Village will need to compile all the existing documents and programs and incorporate them into one document. There will need to be several minor updates to the existing programs such as the Overflow Response Plan (ORP) to comply with all the CMOM requirements. There are extensive capital improvement projects currently being implemented based on the extensive inspection work that has been completed. Operations and Maintenance activities has been undertaken, and additional documentation maybe required to meet include all O&M work practices and responsibilities. For more details, refer to the Readiness Review Report submitted to the Village in January 2006.

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Major CMOM Program Implementation TasksThe Village of Whitefish Bay has the majority of the CMOM Plan elements in place and compiling this information under one document will provide the framework for the CMOM Plan. Management Programs 1. Policies and Procedures. The Village has the majority of the CMOM programs in place. There are some documented policies and procedures and the Village is working on finalizing these policies and procedures. 2. Fats Oil and Grease (FOG). This program currently is not part of the Public Works department. Review of this program should be completed and a FOG program developed including annual inspections. Coordination of this program between the health department and the public works should be implemented. Inspections need to be documented and public education enhanced to educate Village departments regarding the impact of FOG on the sewer system. 3. Customer Service and Complaint Program. The existing program is in place. The program needs to be reviewed and updated as necessary. The existing program reviews the complaints and addresses the solution via an inspection, cleaning or CIP project. 4. Legal Programs. There are many legal programs that are necessary to ensure that the Village will be able to legally enforce their program and eliminate clear water from the system. a. Review and update the Sewer Use Ordinance (SUO). b. FOG. Review program and determine if any revisions to ordinances will be required. c. The Village has recently requiring that property owners replace laterals if the sewer is being replaced. This program has just been implemented. 5. Training. Most of the training is done on the job. Specific training appropriate to the equipment should be developed. The Village currently has a cleaning truck and TV unit. Annual inspection of the cleaning truck and cleaning pressures should be performed by the manufacturer. 6. Capital Improvements Plan. The Village has completed many capital improvements over the past years and has a comprehensive CIP in place. 7. Safety Program Review and enhance and necessary. Program is well documented in most parts and reviewed on an annual basis. This level of effort should be continued with this level of effort and enhanced by scheduling safety tail gate meetings. Operation and Maintenance Programs 1. Inspection Program. The existing sewer and manhole inspection programs are in place and documented. A 10 year CIP has been implemented using the information from these inspections. The Village should continue this comprehensive approach. Other areas to review and potentially update are: a. Review and update the sewer and manhole inspection programs including condition assessment guidelines. b. Review existing sewer and manhole inspection schedules and modify as necessary based on the results of the inspections. c. Review existing inspection forms for manholes and sewers and update as necessary.

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FINAL d. Review and update the inspection program for maintenance of right of ways and easements. e. Continue to use the condition assessment information to provide recommendations for repairs, rehabilitation and replacement. 2. Cleaning Program. The current program is in place and half of the system is cleaned every other year and the schedule has recently been changed to cleaning one-third the sewers each year and the work is documented. The documentation of this program should be reviewed to ensure that the data is being used effectively. a. Review existing cleaning form and enhance as necessary. b. Review any frequently visited areas to determine why these areas need to be cleaned more frequently. c. Develop procedures to verify if the sewers have been cleaned properly via inspection spot checks. d. Develop guidelines to determine cleaning cycle for each basin and review on an annual basis. The Village is currently doing this informally, but needs to be documented. System Evaluation and Capacity Assurance Plan (SECAP). 1. System Evaluation and Capacity Assurance Plan (SECAP). The system flows have been previously modeled. Based on these results, recommendations for sewer and manhole rehabilitation projects were incorporated into the CIP. The Village has been implementing these projects. Use the template provided by MMSD to provide guidance for the plan if a SECAP is required.

Overflow Response Plan. 1. Overflow Response Plan. The Village has a written procedure to address overflows. This procedure should be reviewed and enhanced as necessary to address overflows and other wet weather responses. These procedures are documented and mock drills are performed. The Village can use the template provided by MMSD as a guideline for this plan to expand as necessary. The MMSD Stipulation and amended rules require satellite municipality CMOM adoption within two years of MMSD initiating its CMOM Program. MMSD will complete all activities essential to CMOM Implementation, including CMOM Rule adoption, by June 30, 2007, the Village must implement its CMOM Program by June 30, 2009. At a minimum, the Village will need to develop the following documents by that date: 1. 2. 3. 4. 5. 6. Management Plan Overflow Response Plan Communications Plan Audit Plan Annual CMOM Report Operation and Maintenance Plan including procedures for the sewer collection system

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FINAL The above documents do not represent completion of the Village CMOM Program. As CMOM is a cyclical process, the Village will regularly update these documents as necessary so they accurately reflect how the system is being managed, operated, and maintained. In addition, the Village will work to make the improvements identified in the Readiness Review according to the priorities established during that process. The 5-Year CMOM Audit will serve to evaluate the progress that has been made in these areas.

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Chapter 1 - Strategy IntroductionThe Village of Whitefish Bay has initiated a Capacity assurance, Management, Operations and Maintenance (CMOM) program in order to determine a strategic direction for developing and implementing best business practices in the areas of capacity management, organizational management, and operations and maintenance (O&M). These desired best business practices are fundamental to delivering wastewater collection services. Other practices that would address larger Village organizational issues (e.g., personnel management and asset management) are not included in this project. The Village may consider developing a process or procedure to address these other organizational issues. Section 1.3 summarizes specific activities the Village currently practices which fulfill the likely