John Wiemhoff, Senior Environmental Engineer Water Division; NPDES Permit Branch USEPA, Region V, Chicago

These earlier regulations had Federal Grant Conditions as part of the Construction Grants Program which was providing Federal and State Grants for collection systems and master plan wastewater treatment plant expansions or upgrades The Conditions of Grant Funding for new conveyance and treatment systems included: A demonstration by the Grantee that the sewer system is not, or will not be, subject to excessive infiltration and inflow (I/I) Initial Screening Levels for excessive I/I were listed as: 120 gallon per capita per day for base flow plus infiltration; and 275 gallons per capital per day for base flow plus infiltration plus inflow

Inflow: Water other than wastewater that enters a sewer system (including sewer service connections) from sources such as, but not limited to, roof leaders, cellar drains, yard drains, area 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. Infiltration: Water other than wastewater that enters a sewer system (including sewer service connections and foundation drains) from the ground through such means as defective pipes, pipe joints, connections, or manholes. Infiltration does not include, and is distinguished from, inflow.

Makes for higher costs to transport and treat wastes using funds which could be more well utilized elsewhere; likely more financially prudent to remove excessive I/I Increases the likelihood of collection system overflows (SSOs, basement backups, etc.) Consumes plant capacity which may stifle growth and/or require earlier capital expenditures to add capacity to the wastewater treatment system Increases Potential Liabilities: Increased potential violations from overflows in collection system, Increased claims stemming from basement backups, Increased stressing of wastewater treatment operations, and increased likelihood of wastewater treatment plant NPDES permit discharge limit violations

Bad publicity for the liabilities listed above

 Public Sector I/I sources Private Sector I/I Sources

Regulatory Agency Interests

Remove the problematic I/I

which is causing violations, basement backup and other potential violations

Developing a sewer use ordinance or other legal mechanism that will allow for identification (and elimination) of Private Property Inflow (or Infiltration) sources Some communities require internal home sewer drain plumbing Inspections as part of any property transfers or ($$) as a requirement of permitted threshold home improvement projects Have tickler from property transfer documents or building permits Providing some form of financial incentives to home owners to disconnect clear water inflow connections from the sanitary sewer systems to storm drainage Leaky lateral inspection and televising Find out what others are doing: http://www.wef.org/privateproperty/ http://www.stlmsd.com/aboutmsd/organization/consentdecree/pvt-iireduction.pdf Public Outreach to make citizens aware of the why

Some form of Sewer System Management Program Some form of Sewer System Assessment (SSA) System Evaluation and Capacity Assurance Plan (SECAP); as used for Wisconsin communities with potential excessive I/I; Local Example: http://v3.mmsd.com/AssetsClient/Documents/CMOM/MMS D_CMOM_Program_Ch_5_System_Evaluation_and_Capacity _Assurance_Plan.pdf Capacity Management, Operations, and Maintenance (CMOM) Plan Consistent with procedures and guidance outlined in U.S. EPAs Guide for Evaluating CMOM Programs at Sanitary Sewer Collection Systems, EPA 305-B-05-002 (January 2005).

http://www.cmom.net/cmom_guide_for_collection_systems.pdf

One Enforcement Example Satellite Community of East Bay Municipal Utility District (EBMUD):
1. City submitted an Inflow Identification and Reduction Plan to State and Federal EPA; 2. This term of this stipulated order (by CA and USEPA) requires the City to implement this plan as it was provided and approved;

Example: Excerpt from Stipulated Order; City of Alameda, CA Filed 03/15/11; Region 9