APPLICATION NOTE

by Susan McHugh, Marsh-McBirney, Inc.

The United States Environmental Protection Agency (EPA) continues to develop proposed National
Pollutant Discharge Elimination System (NPDES) permit requirements for capacity, management, operation
and maintenance (CMOM) programs for municipal sanitary sewer collection systems. The current EPA
regulations (Part 122 EPA Administered Permit Program; NPDES) have been modified with specific
reference to Municipal Satellite Sewer Collection Systems, Municipal Sanitary Sewer Systems, Capacity,
Management, Operation and Management Programs (CMOM), Prohibition on Municipal Sanitary Sewer
System Discharges, and Record Keeping and Reporting for Municipal Sanitary Sewer Systems. CMOM will
affect all separate sanitary sewer systems including satellite collection systems.

General Overview of the New CMOM Regulations

The new regulations are establishing a regulatory framework for applying NPDES permits to municipal
satellite collection systems: sanitary sewers owned or operated by a municipality that convey wastewater to
a publicly owned treatment works (POTW) that has a treatment plant owned or operated by a different
municipality. Poorly performing satellite collection systems often contribute to sanitary sewer overflows
(SSOs) which go unreported to the NPDES authority and are often a major contributor to peak flow
problems in regional collection systems. The new permit conditions will include recordkeeping, reporting,
public notification, Capacity Assurance, Management, Operation and Maintenance (CMOM), emergency
response, and audit requirements for all municipal sanitary sewer collection systems.

There are four major documentation requirements of the CMOM permit. Documentation requirements will
vary based on the size and complexity of the municipal wastewater collection system and will include:

1. A written summary of the CMOM Program

2. An Overflow Emergency Response Plan
3. A Program Audit Report
4. A System Evaluation and Capacity Assurance Plan

Addressing the Prohibition of Sanitary Sewer Overflow (SSO) Discharges for CMOM

Within the new ruling, there is a general prohibition of SSO discharges. Essentially, if a SSO occurs, the
Permittee must demonstrate that the overflow was unavoidable, that the CMOM was in place and working,
and that all reasonable steps were taken to stop and mitigate the impact of the discharge as quickly as
possible. Under the new rules, owners must properly manage systems at all times by providing adequate
capacity for peak flows in all parts of the system, taking all feasible steps to:

Mitigate SSOs
Keep written records on SSOs
Report on Discharge Monitoring Reports
Provide 24-hour reporting of SSOs
Keep written follow-up records
Provide public notification of SSO or backup
Prepare an annual report
Develop a CMOM audit program
 Make the CMOM available for public review

This program will require owner certification that all appropriate measures are being taken to eliminate
unauthorized SSOs and backups, and that the CMOM Program is being followed and implemented. In order
to address the variety of SSO problems, EPA and the States will be targeting facilities where sewage
overflows cause or have the potential to cause problems due to poor O&M practices. Facilities need to
conduct a thorough self-audit and assessment of their entire sewer system and develop a plan to correct
problems over a reasonable time period.

Why Flow Monitor for Sanitary Sewer Assessment?

The objective of the sanitary sewer is to convey only the sanitary flow into treatment plants. Unintended
infiltration and direct inflow (I/I) of storm water are extraneous flows and should be minimized as they
reduce the available capacity to transport wastewater. The System Evaluation and Capacity Assurance
Plan, of which Flow Monitoring is the primary step, is needed to identify, characterize and address hydraulic
deficiencies in the collection system. Generally the plan should address:

Collection and analysis of appropriate information on the management

and performance of your collection system
Development of management and performance objectives and goals
of your collection system
Clarification of management and performance objectives
Selection and implementation measures
Development and evaluation of alternatives
Continued monitoring, assessment, and adjustment of implemented measures

Flow Monitoring is a cost-effective method for maximizing the use of existing sewer infrastructure. Flow
Monitoring provides valuable information about the actual flows conveyed. Owners can be made aware of
the variables in sewer flows due to unknown and improper connections, the conditions of joints, cracks, and
the susceptibility to allow ground and surface infiltration and inflow.

Sources of flow in the sanitary sewer include 'domestic' dry-weather flow and other extraneous (unintended)
inflows. Identifying the sources of extraneous flows into the sanitary sewer is an important step. The
hydrograph of sanitary sewers is made up with the following components:

Baseflow Source
The waste flow generated from 'normal' residential, commercial and
industrial operations, known as dry-weather flow.

Infiltration Source
Originates in part from groundwater leakage into the sewers and from rainfall-induced surface seepage
through the soil cover.

Inflow Source
The direct contribution of storm water through openings in manhole covers, directly-connected roof drains,
sump-pumps or other storm-related elements such as catch-basins or drain-pipes.

Flow Monitoring
(From the EPA’s CMOM Program Assessment Checklist)

Many communities have some or no written documentation of their sewer maintenance program. The EPA’s
Office of Wastewater Management (OWM) is developing a toolbox to help communities develop and
implement better CMOM programs. These questions, among others, are part of a CMOM program checklist
to assist municipalities in their compliance efforts:

• How many permanent flow meters are currently in the system?

• Does the utility have a flow monitoring program?

• Are flows measured prior to allowing new connections?

• Is there a process to determine the ability of the sewer system to carry additional flow from new
connections?

• What is the ratio of peak wet weather flow to average dry weather flow at the wastewater treatment
plant?

• How many temporary flow meters are in the system?

• Are records maintained for each inspection?

• Do the flow meter checks include the following?

o Velocity reading
o Independent water level
o Downloading data
o Cleaning away debris
o Checking the desiccant
o Battery state

• Do the flow monitoring records include the following?

o Location Frequency of flow meter inspection
o Type of flow meter Frequency of flow meter calibration
o How frequently are the meters checked? (e.g. weekly, monthly, etc.)

Tracking Sanitary Sewer Overflow (SSO)

(From the EPA’s CMOM Program Assessment Checklist)

These questions appear in the SSO/CMOM toolbox to assist municipalities in addressing SSO abatement:

How many chronic sanitary sewer overflow (SSOs) locations are in the system?

How many SSOs have occurred in the past 5 years?

What percent of the SSOs in the past 5 years were less than 1,000 gallons?

Approximately what percent of SSOs discharge is from the following?

• Manholes
• Pump stations
• Structural bypasses
 Does the utility include basement backups in the number of SSOs per year?

Are there areas that experience frequent basement or street flooding?

Overflow Emergency Response Plan (OERP)

(from the EPA’s CMOM Program Assessment Checklist)

Do overflow records include the following information?

Names of effected receiving waters

• Date and time

• Cause
• Estimated flow
• Any remediation efforts
• Location
• How it was stopped
• How often is the OERP reviewed and updated?

EPA’s Region 4 has additionally put together a checklist for utilities performing a CMOM self audit2. Again,
Flow Monitoring is stressed as a tool for system assessment and capacity assurance:

Continuing Sewer System Assessment Program

Sewerage Assessment Priority Parameters

(used to set assessment priorities)

ii. Flow Monitoring

iii. Overflows
vi. Preliminary Sewer Assessment

Flow Monitoring Program to Support Engineering Analyses (37)

i. Permanent Flow Meters

ii. Temporary Flow Meters
iii. Sewer Cleaning Associated with Flow Monitoring
iv. Midnight Flow Observations (Wet/Dry)
v. Rainfall Measurement
vi. Flow Monitoring Information Management

System Capacity Assurance Program

 Projected Flow Impact Modeling/Calculation Techniques

i. Hydraulic Model of Gravity System

ii. Limited by Pipe Diameter

How-To’s of Flow Metering for CMOM Compliance

A typical monitoring period varies from a minimum of three months, to a maximum of six months. In most
instances, it is critical that both the spring melt and a range of summer storm events are captured in the
monitoring programs. In order to perform a detailed analysis of infiltration/inflow and pipe capacity, it is
necessary to obtain flow-monitoring information during both dry and wet weather. Under ideal conditions,
multiple rain events of varying intensities are monitored in order to accurately assess the inflow response for
each event. Information obtained during the monitoring period can be used to determine the following:

Average daily flow - dry weather

Peak flow - dry weather

Average daily flow - wet weather

Peak flow - wet weather

Peak inflow rates

Total I/I volume

Meter site selection can be accomplished after reviewing the collection system maps and preliminary field
inspection of any sanitary sewer overflow (SSO) locations. Each monitoring site should be selected so that
the footage of the collection system upstream of the meter can be isolated for the purposes of determining
extraneous infiltration/inflow. Installation of rainfall meters across the study area to measure rainfall intensity
and duration throughout the monitoring period can assist in establishing wet weather capacity for SSO
analysis. Two basic sewer channel flow meter technologies are available: (1) “Wetted sensors”, or
submersible sensors, where the level/velocity sensor is mounted in the flow stream and the sensor is
secured to a mounting band that fits snugly in the pipeline and (2) “Non-contact” radar sensors, where the
sensor is mounted in a level position above the flow stream ensuring that the radar signal is aimed at the
flow and does not hit invert walls. A data logger is installed at the top of the manhole. For the most accurate
data, flow direction should not change abruptly going through the manhole. The manhole should not have
debris, brick or any other objects that might disrupt the flow.

Reporting:

After the primary discharge locations have been established, it is important that a flow balance calculation is
completed to identify system problems and quantify flow volumes and contribution percentages. Flow
balance calculations will indicate system constraints and problems at a glance. Tabular reportsl allow the
system to be assessed using volumetric techniques, allowing for complete site-by-site quantification. Scatter
plot analysis determines if capacity issues are due to upstream backwater conditions or downstream system
hydraulics. Scatter plot shapes clearly indicate if base flows are present and how much. Scatter plots also
indicate if the system is conforming to conventional gravity flow conditions or to a combination of open
channel and closed pipe flow hydraulics. Flow Monitoring Program Reports should include site reports for
each station, a summary of data collected at each monitoring station and discussions of the following:

Dry weather analysis (including calculated base flows and diurnal patterns)

Wet weather analysis (including locations impacted by I/I and to what degree)

Tables and figures necessary to explain the results and findings

Conclusions & recommendations

Hydrographs and tabular data for each station for the monitoring period

Develop Your Flow Monitoring and CMOM Programs

Formal development of a CMOM program is critical for all communities that experience any SSOs no matter
how rare. The EPA has set a standard of care that must be implemented. Any overflows that are associated
with events that should not have occurred with proper O&M practice will now be considered a violation that
is subject to monetary and legal fines.

With the proposed modifications to USEPA regulations establishing NPDES requirements to develop and
implement CMOM programs for POTWs and satellite collection systems, you may be asking yourself how
you can comply with the regulations and be efficient at the same time. The answer: A Flow Monitoring
Program will ensure accurate measurement of local hydraulics, base flows and capacity. Planning and
establishing a Flow Monitoring Program in conjunction with an ongoing CMOM program will bring your
wastewater collection system into compliance with USEPA regulations and NPDES requirements.
Remember, the CMOM program will act as the primary mechanism for potentially offsetting an enforcement
action. As an added benefit, your CMOM program will result in a more efficient, better run collection system.
Flow metering as a component of CMOM and ongoing sewer system investigations will assist municipalities
in optimizing all aspects of the system’s hydraulic performance.