Document 9J0eE38mJ55E8kQ18Yk0gQ9Nq
ABCWUA/Southside Water Reclamation Plant (SWRP) NPDES Permit No. NM0022250 Albuquerque, New Mexico Inspection Date 09/21/2022
Region 6 - Enforcement & Compliance Assurance Division
INSPECTION REPORT
Inspection Date(s):
09/21/2022
Media Program:
Water
Regulatory Program(s)
NPDES
Company Name: Facility Name: Facility Physical Location:
(city, state, zip code) Mailing address:
(city, state, zip code) County/Parish: Facility Phone Number Facility Contact:
Albuquerque Bernalillo County Water Utility Authority (ABCWUA)
Southside Water Reclamation Plant (SWRP)
4201 2nd Street SW
Albuquerque, NM 87105
Post Office Box 568
Albuquerque, NM 87103
Bernalillo
505-289-3382/505-803-1970
Danielle Shuryn
Compliance Division Manager
dshuryn@abcwua.org
FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: SIC:
110000567075 NM0022250 NA 221320 4952
Personnel participating in inspection:
Steve Lujan
ABCWUA
Merat Zarreii Danielle Shuryn Meghan McDonnell, P.E. Shawn Hardeman
ABCWUA ABCWUA ABCWUA ABCWUA
Mark Holstad, P.E Jared Ray Stan Allred Johanna Malouff Hobert Warren David A Esparza, P.E.
ABCWUA ABCWUA ABCWUA ABCWUA ABCWUA R6-ECDWM
Asst. O/M Superintendent Water Reclamation -Operations NPDES Program Manager Compliance Division Manager Quality Assurance System Manager Water Quality Laboratory Program Manager Chief Engineer-Field OPS/Main Supt Maintenance Operations & Business Services Senior Engineer-Field Fieldplant Division Manager Environmental Engineer
EPA Lead Inspector Signature/Date
DAVID ESPARZA
David Esparza
Digitally signed by DAVID ESPARZA Date: 2022.11.22 11:52:14 -07'00'
09/21/2022
Supervisor Signature/Date
ROBERTO BERNIER Date: 2022.11.28 08:18:04 -06'00' Digitally signed by ROBERTO BERNIER
Roberto Bernier
Date
6ENFORM-019-R8.2 (02/12/2020)
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ABCWUA/Southside Water Reclamation Plant (SWRP) NPDES Permit No. NM0022250 Albuquerque, New Mexico Inspection Date 09/21/2022
Section I - INTRODUCTION
PURPOSE OF THE INSPECTION
EPA Region 6 inspector David Esparza arrived at the Albuquerque Bernalillo County Water Utility Authority (ABCWUA)Southside Water Reclamation Plant (SWRP) at 8:30 AM on September 21, 2022, for an unannounced Compliance Evaluation Inspection (CEI). We met with Steve Lujan, ABCWUA Asst. O/M Superintendent Water Reclamation Operations, Mark Holstad, P.E, ABCWUA Chief Engineer-Field, Ms. Danielle Shuryn, ABCWUA Compliance Manager, Merat Zarreii, ABCWUA NPDES Program Manager, Ms. Meghan McDonnell, P.E. ABCWUA Quality Assurance System Manager, Jared Ray, ABCWUA OPS/Main Supt Maintenance, Ms. Johanna Malouff, ABCWUA Senior Engineer-Field, Hobert Warren, ABCWUA Fieldplant Division Manager, Stan Allred, ABCWUA Operations & Business Services and Shawn Hardeman, ABCWUA Water Quality Laboratory Program Manager. I presented his credentials to Mr. Holstad and informed him that this was an EPA inspection to determine the SWRP's compliance under the Clean Water Act (CWA). This CEI was conducted under the authority of the National Pollutant Discharge Elimination System (NPDES) permit program, in accordance with the CWA. The generation of this report is based on information supplied by ABCWUA representatives, observations made by the United States Environmental Protection Agency (US EPA) inspector, and records and reports maintained by the permittee (ABCWUA), and the US EPA. Before leaving the facility, an exit briefing was held with Mr. Steve Lujan, Asst. O/M Superintendent Water Reclamation -Operations, and the above-mentioned staff representatives, to explain areas of concern noted at the time of the inspection and discuss the Capacity Management Operations and Maintenance (CMOM) checklist forwarded via electronic mail (email) earlier in the morning.
FACILITY DESCRIPTION
The ABCWUA SWRP is located at 4201 Second Street SW in the City of Albuquerque, Bernalillo County, New Mexico ((depicted in Aerial Image #1 below). Coordinates to the SWRP facility are Latitude 35 01' 04" North and Longitude - 106 40' 13" West.
The ABCWUA SWRP design capacity is 76 million gallons/day (MGD). Present flows average about 55 MGD. The population served is approximately 600,000 with an industrial flow contribution of about 15%. The facility operates two (2) shifts and is open 24 hours/7 days per week. The shifts are comprised of 5-operators and 2 supervisors. The entire facility is gated, and limited access is maintained.
The existing treatment process contains: Head works - 6 mechanical bar screens of which 2 are low level screens and 4 are high level screens (with a capacity of 20 MGD each), Grit Chambers - 5 grit removal structures (3 vortex units and 2 aerated chambers), Clarification - 8 primary clarifiers together with 4 north and 8 south final clarifiers. Each clarifier is circular with a conic design having a side wall depth of 13 feet. Reported capacity of each clarifier is 1.6 million gallons. All clarification units are equipped with surface skimmers and sludge scraper assemblies. Aeration Basins - 14 aeration basins (each basin contains 3 anoxic zones followed by 2 swing zones 3 oxic zones, 1 dissolved oxygen control zone and a recycle pump). Additionally, the anoxic and swing zones are equipped with 1 vertical shaft mixer and two shaft mixers in the swing zone, respectively. The oxic zones are aerated by 12 centrifugal blowers. Four, are in the north blower building and eight are in the south blower building.
The SWRP utilizes Ultra-violet light to disinfect the treated effluent prior to discharging to Outfall 001 and into the Rio Grande.
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ABCWUA/Southside Water Reclamation Plant (SWRP) NPDES Permit No. NM0022250 Albuquerque, New Mexico Inspection Date 09/21/2022
The SWRP maintains and operates 38 sanitary lift stations (LS) and 10 vacuum stations (Identified in Table 1 and Table 2 below). Additionally, the facility maintains back-up power to all LS and vacuum stations, inclusive of a quarterly testing program.
Aerial Image 1: Overall view of the ABCWUA's Southside Water Reclamation Plant (SWRP). Aerial provided by ABCWUA.
Table 1: ABCWUA Sanitary Lift Stations
Station Number
302 304 305
306 307
Location
924 Commercial St.SE 2265 Arenal SW
2600 New York NW 915 Broadway Blvd NE 621 Heather Lane SW
Status
active active active active active
Back-up Power (type)
Quick connect Quick connect Quick connect
Quick connect Quick connect
6ENFORM-019-R8.2 (02/12/2020)
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308
2860 Rio Bravo Blvd SW
309
210 Sandia View Rd NW (Osuna) & 2nd
310
2700 Blake Road SW
312
5801 Barr Rd. SW
313
7400 Paseo Del Volcan NW
314
7230 Paseo Del Volcan NW
315
501 Rossmoor Rd SW (MH)
316
1600 Douglas MacArthur Rd NW (MH)
317
2709 Apple Valley SW
318
Balloon Fiesta Park, E of AMAFCA north
diversion channel
319
2260 Hooper & Foothill Rd SW (MH)
320
3914 Isleta Blvd SW
322
1815 1/2 Gonzales Rd SW (MH)
323
3401 Duranes Rd NW
324
4080 Learning Rd NW
325
8601 4TH St. NW (MH)
326
10123 2ND St. NW (MH)
327
102 Public School Rd (Tijeras Canyon)
329
7910 1/2 Rio Grande NW & Ranchitos (MH)
352
8305 1/2 Rio Grande NW
353
6847 1/2 Rio Grande NW (MH)
354
1600 1/2 Francisca Rd NW (MH)
355
321 Industrial Ave NE (MH)
356
10036 2nd St. & Sanchez Rd. NW (MH)
358
105 Anderson Ave SE
380
8701 Universe NW (MH) TRAILS
381
10000 Vivald (MH) 6323 Orfeo
382
9500 1/2 Calle Chamisa NW (MH)
383
5800 Mafraq Ave. NW (MH) PARADISE
384
9607 Lyon NW (MH) SUNDANCE
385
10800 Corrales NW (MH)
386
7701 Compass Dr NW (MH)
388
9238 Dawn Patrol Tr. NE
NOTE: (MH) is a designation for manhole
Table 1: ABCWUA Vacuum Stations
Station Number
357 361 362 363 364 365 366 367 368 369
Location
4409 Rio Grande & Montano NW 5816 Isleta Blvd SW
1011 Paseo Del Norte & Chamisal Lateral 2427 Jensen Dr SW 5816 Isleta Blvd SW 101 Alameda Rd NE 2220 Raymac Rd SW 2701 Don Felipe SW
10005 N. Guadalupe Rd NW 7009 Coors Rd SW
active active active active active active active active active active
ABCWUA/Southside Water Reclamation Plant (SWRP) NPDES Permit No. NM0022250 Albuquerque, New Mexico Inspection Date 09/21/2022
Quick connect Quick connect Quick connect Quick connect Onsite generator Onsite generator Quick connect Quick connect Quick connect Quick connect
active active active active active active active active active active active active active active active active active active active active active active active
Quick connect Onsite generator
Quick connect Quick connect Onsite generator Quick connect Quick connect Onsite generator Quick connect Quick connect Quick connect Quick connect Quick connect Quick connect Quick connect Quick connect Quick connect Quick connect Quick connect Quick connect Quick connect Quick connect Quick connect
Status
active active active active active active active active active active
Back-up Power
Quick connect Quick connect Onsite generator Onsite generator Quick connect Quick connect Quick connect Quick connect Quick connect Quick connect
6ENFORM-019-R8.2 (02/12/2020)
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Section II - OBSERVATIONS
ABCWUA/Southside Water Reclamation Plant (SWRP) NPDES Permit No. NM0022250 Albuquerque, New Mexico Inspection Date 09/21/2022
A review of the ABCWUA completed calendar year 2020 (CY2020) Capacity, Management, Operation and Maintenance (CMOM) Self-Assessment discusses Sanitary Sewer Overflow (SSO) Analysis (Refer to Appendix 2 ABCWUA Capacity, Management, Operation and Maintenance (CMOM) Self-Assessment document- pages 5 thru 11). Additionally, the 2020 CMOM delineates an analysis of Sanitary Sewer Overflow events (ABCWUA CMOMAppendix 1- page 17), inclusive of an analysis of the estimated SSO spill volumes and volumes recovered (ABCWUA CMOMAppendix 2- page 18), related to the 17 SSO events for CY2020.
A review of the ABCWUA completed calendar year 2021 (CY2021) Capacity, Management, Operation and Maintenance (CMOM) Self-Assessment discusses Sanitary Sewer Overflow (SSO) Analysis (Refer to Appendix 2 ABCWUA Capacity, Management, Operation and Maintenance (CMOM) Self-Assessment document- pages 6 thru 11). Additionally, the 2021 CMOM delineates an analysis of Sanitary Sewer Overflow events (ABCWUA CMOMAppendix 1- page 20), inclusive of an analysis of the estimated SSO spill volumes and volumes recovered (ABCWUA CMOMAppendix 2- page 22), related to the 12 SSO events for CY2021.
A review of the ABCWUA completed calendar year 2021 (CY2021) Capacity, Management, Operation and Maintenance (CMOM) Self-Assessment document indicates a mechanism or written protocol in-place pertaining to Overflow Emergency Response (OERP) (Refer to ABCWUA CMOM- Appendix 4 - Overflow Emergency Response (OERP)).
A review of the ABCWUA completed calendar year 2021 (CY2021) Capacity, Management, Operation and Maintenance (CMOM) Self-Assessment document indicates a written mechanism in-place pertaining to a Fat, Oils, Grease and Solids (FOGS) protocol (ABCWUA CMOM pages 4, 5 and 13). Additionally, ABCWUA implemented a FOG Advertising Campaign (Refer to ABCWUA CMOM- Appendix 3 - FOG Advertising Campaign)
A review of the ABCWUA completed calendar year 2020 and 2021 (CY2020 & CY2021) Capacity, Management, Operation and Maintenance (CMOM) Self-Assessment document indicates implementation of a Goal Summary as part of their CMOM process (Refer to ABCWUA CMOM- Appendix 5 - Goal Summary - CY2020 or CY2021 Report)
Section III - AREAS OF CONCERN
A review of the ICIS database for the period from January 1, 2020, to September 20, 2022 (Appendix 3) indicates NPDES permit excursions.
A review of the Integrated Compliance Information System (ICIS) indicates several NPDES permit single event violations (January, February, March, April, May, June, July, October, November and December 2020; February, March, April, July, November and December 2021; January, February, March, April, and May 2022), and effluent violations (March, May, June, August, September, and October 2020; January, February, June, September, October, and December 2021; January, April, May, June and July 2022).
The following additional areas of concern (AOCs) were identified after review of the information provided by the Albuquerque Bernalillo County Water Utility Authority :
A review of the ABCWUA completed calendar year 2020 (CY2020) Capacity, Management, Operation and
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ABCWUA/Southside Water Reclamation Plant (SWRP) NPDES Permit No. NM0022250 Albuquerque, New Mexico Inspection Date 09/21/2022
Maintenance (CMOM) Self-Assessment discusses Sanitary Sewer Overflow (SSO) Analysis (Refer to Appendix 2 ABCWUA Capacity, Management, Operation and Maintenance (CMOM) Self-Assessment document- pages 5 thru 11). Additionally, the 2020 CMOM delineates an analysis of Sanitary Sewer Overflow events (ABCWUA CMOMAppendix 1- page 17), inclusive of an analysis of the estimated SSO spill volumes and volumes recovered (ABCWUA CMOMAppendix 2- page 18), related to the 17 SSO events for CY2020.
A review of the ABCWUA completed calendar year 2021 (CY2021) Capacity, Management, Operation and Maintenance (CMOM) Self-Assessment discusses Sanitary Sewer Overflow (SSO) Analysis (Refer to Appendix 2 ABCWUA Capacity, Management, Operation and Maintenance (CMOM) Self-Assessment document- pages 6 thru 11). Additionally, the 2021 CMOM delineates an analysis of Sanitary Sewer Overflow events (ABCWUA CMOMAppendix 1- page 20 of 26), inclusive of an analysis of the estimated SSO spill volumes and volumes recovered (ABCWUA CMOM- Appendix 2- page 22 of 26), related to the 12 SSO events for CY2021.
EPA Region 6 inspectors David Esparza, PE conducted a closing conference at ABCWUA/Southside Water Reclamation Plant (SWRP) at 1:50 PM (MST) on September 21, 2022, for the inspection. Additionally, the SSO events identified in the CY2020 and CY2021 ABCWUA completed CMOM were not included in the closing conference.
Section IV - FOLLOW UP
The following information was received by EPA, after exiting the Facility on September 21, 2022:
1. Organizational charts with respect to departments and staff. 2. Map(s) of the sanitary sewer system 3. Any Standard Operating Procedures (SOPs) pertaining to:
Unauthorized discharge response (Sanitary Sewer Overflows (SSOs)) events, inclusive of reporting procedure, SSO hotspots, memorialization, and work orders.
Lift station locations, and inspections Complaint call responses Fats, Oils and Grease (FOG) Program Inflow and infiltration (I/I) Condition Assessment Capacity assessment Current Budget Current wastewater rates/fees Capital Improvement Program Cleaning and root control program- jetting and/or vacuuming schedule City Ordinances Code enforcement (FOG, MS4, laterals) Asset management program and surveys Operation and Maintenance (O&M) program protocol
Section V - LIST OF APPENDICES
Appendix 1 - Photo Log - 4 photos taken 09/21/2022 Appendix 2 - ABCWUA CY2020 and CY2021 Capacity, Management, Operation and Maintenance (CMOM)
6ENFORM-019-R8.2 (02/12/2020)
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ABCWUA/Southside Water Reclamation Plant (SWRP) NPDES Permit No. NM0022250 Albuquerque, New Mexico Inspection Date 09/21/2022
Self-Assessment
Appendix 3 - Review of the Integrated Compliance Information System (ICIS) Database for the period from January 1, 2020, to August 31, 2022
Appendix 4 - Opening and Closing conference sign-in sheets
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ABCWUA/Southside Water Reclamation Plant (SWRP) NPDES Permit No. NM0022250 Albuquerque, New Mexico Inspection Date 09/21/2022
Appendix 1
Photograph Log
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 1
Location: ABCWUA/Southside Water Reclamation Plant (SWRP)
City: Albuquerque
County/Parish: Bernalillo
State: New Mexico
View of process treatment equipment inside the Course Screening Facility (CSF). (DSCN2320) Photographed by D. Esparza
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 2
Location: ABCWUA/Southside Water Reclamation Plant (SWRP)
City: Albuquerque
County/Parish: Bernalillo
State: New Mexico
View of process treatment equipment inside the Rotating Drum Thickener Facility (RDT). (DSCN2321) Photographed by D. Esparza
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 3
Location: ABCWUA/Southside Water Reclamation Plant (SWRP)
City: Albuquerque
County/Parish: Bernalillo
State: New Mexico
View of ultra-violet (UV) disinfection banks inside the UV Disinfection Building before the Siphon Towers and the eventual discharge to the Rio Grande at Outfall 001. (DSCN2324) Photographed by D. Esparza
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 4
Location: ABCWUA/Southside Water Reclamation Plant (SWRP)
City: Albuquerque
County/Parish: Bernalillo
State: New Mexico
View of several centrifugal drums utilized in the thickening and dewatering of the sludge. (DSCN2326) Photographed by D. Esparza
ABCWUA/Southside Water Reclamation Plant (SWRP) NPDES Permit No. NM0022250 Albuquerque, New Mexico Inspection Date 09/21/2022
Appendix 2
ABCWUA CY2020 & CY2021 Completed Capacity, Management, Operation and Maintenance (CMOM) Self-Assessment Document
CMOM ANNUAL REPORT CY2020
Contents
Capacity, Management, Operations and Maintenance (CMOM) Plan Overview............................................ 2 Report Purpose.................................................................................................................................................................... 2 Permit Requirements........................................................................................................................................................ 3 CMOM Program Self-Assessment................................................................................................................................. 3
FOG Policy................................................................................................................................................................................... 4 FOG Enforcement................................................................................................................................................................ 4
SSO Analyses.............................................................................................................................................................................. 5 Permit Requirements........................................................................................................................................................ 5 SSO Study Team................................................................................................................................................................... 5 Causes & Mitigations ......................................................................................................................................................... 7 SSO Tabulation & Analysis .............................................................................................................................................. 8 Volume Spilled and Recovered ................................................................................................................................... 10
Actions Implemented and On-Going Programs ........................................................................................................11 General .................................................................................................................................................................................. 11 FOG Policy Implementation: ........................................................................................................................................11 Overflow Emergency Response Plan (OERP) ....................................................................................................... 11 Closed Circuit Television (CCTV) ............................................................................................................................... 12 Cleaning Program Goal...................................................................................................................................................13 Force Main Inspection Program ................................................................................................................................. 14 Root Foaming ..................................................................................................................................................................... 14 Odor Complaints ............................................................................................................................................................... 14
Identified Gaps in the Water Authority Processes with Recommendation to Close .................................15 Prohibited Discharges, i.e., SSOs.................................................................................................................................15
Appendices............................................................................................................................................................................... 16 Appendix 1 Sanitary Sewer Overflow Analysis Table ..................................................................................17 Appendix 2 Sanitary Sewer Overflow Volume Captured Analysis Table .............................................18 Appendix 3 Thanksgiving Day News Release..................................................................................................19 Appendix 4 Overflow Emergency Response Plan (OERP) ......................................................................... 20 Appendix 5 Goal Summary - CY2020 Report...................................................................................................21
Page 1 of 21
Capacity, Management, Operations and Maintenance (CMOM) Plan Overview
In accordance with National Pollutant Discharge Elimination System (NPDES) Permit No. NM0022250 (Permit), the Albuquerque Bernalillo County Water Utility Authority (Water Authority) prepared this Capacity, Management, Operations and Maintenance (CMOM) Plan. The Permit was renewed in CY2019 with an effective date of December 1, 2019. The CMOM Plan consists of the following documents:
1. FOG Policy 2. CMOM Annual Report 3. CMOM Program Self-Assessment The CY2020 CMOM Annual Report follows previous FY2013-17 and CY2017-19 reports. The previous reports, as well as the most recent, can be accessed at https://www.abcwua.org/sewersystem-overview/. Appendix 4 provides a summary of goals established in this CY2020 CMOM Report. Report Purpose As indicated by its name, the CMOM Annual Report will be reissued to describe CMOM activities in the previous calendar year (January 1 to December 31). The CMOM Annual Report provides summary descriptions of CMOM activities (past and planned) and is intended to be a communication tool. The report is intended for Water Authority staff, regulatory authorities, customers, and the general public.
Page 2 of 21
Permit Requirements The Water Authority discharges to the Rio Grande under authority of NPDES Permit No. NM0022250 (Permit). Under this Permit, the Water Authority operates the Southside Water Reclamation Plant (SWRP) and the Collection System. The Permit was renewed effective December 1, 2019. The following are the Permit requirements that impact the collection system.
1. The Water Authority shall report all overflows with a (monthly) Discharge Monitoring Report (DMR). (Part I, Paragraph D).
2. Overflow reporting requirements were unchanged for EPA and NMED. (Part I, Paragraph D).
3. Overflow reporting requirements were modified for spills impacting the Pueblo of Isleta (POI) were modified in accordance with the "Pueblo of Isleta Reporting Requirement" which were a subsection of the renewed Permit. (Part I, Paragraph D and "Pueblo of Isleta Reporting Requirement".)
4. The Water Authority shall continue to implement and update (if necessary) the CMOM plan. (Part II, Paragraph E.)
The full permit is available at https://cloud.env.nm.gov/water/pages/view.php?ref=6881&k=fd428af5b1 CMOM Program Self-Assessment EPA states (see https://mwrd.org/sites/default/files/documents/USEPA_3-cmomselfreview.pdf): "An important component of a successful CMOM program is to periodically collect information on current systems and activities and develop a "snapshot-in-time" analysis. From this analysis, the utility establishes its performance goals and plans its CMOM program activities." The Water Authority developed Self-Assessments as a part of the FY2013 and FY2014 reports. Because the data provided in the Self-Assessment does not significantly change year-to-year, the Water Authority has set a goal of updating the Self-Assessment every five years.
Therefore, the CMOM Program Self-Assessment CY2018 has been prepared and posted to https://www.abcwua.org/sewer-system-overview/ along with the CMOM Reports. Rather than being an appendix to the CMOM Report, it is now a stand-alone document.
The next update will coincide with the CY2023 CMOM Report.
Page 3 of 21
FOG Policy
The Water Authority's FOG Policy is a separate document. The FOG Policy was developed as a requirement of the NPDES Permit effective on October 1, 2012 and subsequently approved by the United States Environmental Protection Agency (EPA). The policy was developed to work in conjunction with the Water Authority Sewer Use and Wastewater Control Ordinance (SUO) and Enforcement Response Plan (ERP) to reduce the rate of SSOs in the collection system and decrease FOG loading at the SWRP. The policy describes expectations for FOG dischargers such as Food Service Establishments (FSEs) and waste haulers, and the steps the Water Authority is taking to mitigate FOG.
The FOG Policy sets a Water Authority goal of inspecting every FSE at least once every three years. Details of what is expected of the FSE in terms of Grease Removal System (GRS) functionality, pumping schedule, maintenance, and recordkeeping are identified. The FOG policy explains the Water Authority use of the 25% solids and grease rule (25 Percent Rule) to determine if a GRS is filled to capacity. The policy also contains Best Management Practices (BMPs) such as scraping plates, using screens, and not using emulsifiers, etc.
Pumper requirements are also covered in the FOG Policy. Full evacuation of a GRS is required each time pumping occurs. The pumper must leave the FSE documentation in the form of manifests that contain pertinent information such as date, time, volume pumped, and the condition of the GRS. The FOG Policy lists the minimum service to be provided by the pumper.
Enforcement of FOG violations and hauled wastewater violations is described in the FOG Policy. The FOG Policy works in conjunction with the ERP to set administrative assessments for violations.
The FOG Policy also sets forth the process for identifying new sources of FOG. The Water Authority Pretreatment Program will update the FOG database on an annual basis. The FOG Policy sets a goal that the Water Authority will meet with the City of Albuquerque, Bernalillo County, the Village of Los Ranchos, the Village of Corrales, plumbers, and the New Mexico Restaurant Association on a periodic basis to discuss FOG issues.
In developing the FOG Policy, the Water Authority held a meeting with the hauled wastewater permit holders on July 22, 2013 and a public meeting on July 25, 2013 to discuss the proposed Policy. The final FOG Policy was submitted to the EPA on September 27, 2013 and updated in the Pretreatment Program modification documents sent to EPA on June 2, 2014. No comments from EPA were received regarding either submission, thus indicating approval.
FOG Enforcement In CY2020, the Water Authority Pretreatment Program had 1,725 compliant FSEs out of 2,151 FSE sites for a compliance rate of 80%. Seventy-three (73) FSE inspections were conducted with 46 passing, and 27 failing. Of the 27 failed inspections, 21 Notices of Violation were issued. Eight (8) of the 21 violations were resolved and the remainder are outstanding.
In response to SSOs, ten (10) FSE inspections were conducted with three (3) passing and seven (7) failing. Of the seven (7) failed inspections, three (3) Notice of Violations were issued and four (4) were corrected before issuance of violations.
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In addition, Water Authority Pretreatment personnel distributed FOG brochures to FSEs, singlefamily residences and apartment complexes upstream of the SSOs. Additionally, the Water Authority's Public Information Office advanced radio, print and television public outreach for the purpose of improving the Water Authority's FOG Policy.
SSO Analyses
Permit Requirements The Permit requires a CMOM Plan. The Plan goal is to reduce SSOs. The FOG Policy states that the Pretreatment Program will investigate all SSOs related to large amounts of grease. The policy is to take enforcement actions for violations of FOG requirements with priority on FSEs causing repeat SSOs. SSO Study Team To meet these requirements, the Water Authority created an SSO Study Team. The Team is comprised of:
1. Collection Section - Research Analyst (team lead), Gravity Superintendent, Assistant Superintendent and Closed Circuit Television (CCTV) Supervisor;
2. NPDES Pretreatment -Industrial Pretreatment Engineer and Pollution Prevention Specialist.
The Mission Statement for the Study Team is: The SSO Study Team will work inter-divisionally to study, analyze and determine causes of previous SSOs to mitigate future SSOs in the Collection System. The Study Team procedure is:
1. Tabulate all 10-40s, 10-42s and 10-48s (see Table 1 for definitions). 2. Ensure all segments responsible for causing 10-42s and 10-48s are televised. 3. The Research Analyst will review and analyze all CCTV inspections to determine
causes (if possible) and document findings. 4. To conduct meetings with the SSO Study Team to review and analyze CCTV that
needs further investigation for resolution. 5. Recommend/implement and document mitigations (if possible) based on analysis. 6. Coordinate with NPDES Pretreatment concerning grease issues discovered during
analysis.
Page 5 of 21
10-40 10-42
Sewer Backup SSO Reportable
Table 1 Sewer Trouble Definitions
Sewer Trouble Definitions A gravity line blockage that does not result in a spill, or in the vacuum system, a low vacuum (low vac) that causes a customer service disruption. Does not result in an SSO Reportable (10-42) or a Property Damage (10-48). An overflow of sewage from the system that may impact surface waters. These are reported to the EPA and other locally impacted stakeholders.
10-48 Property Damage
An overflow of sewage from the system that results in damage to private property. These are not reportable under current definitions.
Appendix 1 identifies all 10-42s and 10-48s, and the overflows that resulted in both a 10-42 and a 10-48. When documenting the number of Sewer Troubles of different types, for example in Figure 1 and Figure 2, the 10-42 item includes all overflows that may impact surface waters, including those that also had property damage; the 10-48 item includes overflows that only resulted in property damage. This prevents double-counting the number of overflow occurrences.
All 10-40s, 42s and -48s were CCTV inspected, although only 10-42s are "reportable", i.e., required to be reported to the EPA, et al. All 10-42s and -48s were then examined by the Study Team and a Cause and Mitigation were determined.
Table 2 Types of Causes for SSOs
Cause(s) of SSO from DMR
CO - Construction
DB - Debris
CU-Cause Unknown RK-Rocks
EQ - Equipment
GR -
Failure
Grease
SGG-Sand, grit or
gravel
RT - Roots
RN -
LF - Line Failure
Rainfall
V - Vandalism
RGS-Rags
RGR - Roots / Grease BP-Burped
Causes determined from CCTV SC - Surcharged SL - Sag in Line
IT - Intruding Tap
MH - Manhole
OJ - Offset Joint
Page 6 of 21
Causes & Mitigations The Cause(s) were selected from Table 2 that identifies SSO causes from the DMR and CCTV. The monthly SSO DMR has a specific list of Causes that are based on system observations made by an Operator or Supervisor at the site of an SSO. The CCTV data provided to the Study Team often results in a different, more refined Cause or Causes. Table 3 provides the causes determined by the Study team for CY2020. (Note: Percentages may not add up to 100%, as they are rounded to the nearest percent.)
Table 3 Summary of Causes from SSO Study
10-42, 10-48 Causes Burp Construction Debris Grease Grease\Rags Grease\Sag in Line Line Failure Roots\Grease Roots Sag in Line Vandalism Equipment Failure Grand Total
Total % of Total
1
4%
5
21%
1
4%
2
8%
2
8%
1
4%
4
17%
1
4%
3
13%
2
8%
1
4%
1
4%
24
100%
Mitigations are the steps that the Team identified to prevent a recurrence of an SSO, at least for the identified Cause. Specific Mitigations are very dependent on the conditions observed from the CCTV video and report. In CY2020, 33% of mitigations included performing rehab or replacement of the line, whereas in CY2019 more segments were added to the short interval cleaning program. This indicates the condition of infrastructure where SSOs are occurring. Table 4 provides a summary of the various Mitigations. The Mitigations are tracked through completion or implementation. (Note: Percentages may not add up to 100%, as they are rounded to the nearest percent.)
Table 4 Summary Mitigations from SSO Study
10-42, 10-48 Mitigations No Follow Up Needed Pretreatment Notified Pretreatment Notified/Special Instructions Repaired Rehab/Replace Special Cleaning Short Interval Short Interval/Rehab/Replace Short Interval/Special Instructions Special Instructions Grand Total
Page 7 of 21
Total % of Total
4
17%
1
4%
1
4%
2
8%
8
33%
1
4%
2
8%
1
4%
3
13%
1
4%
24
100%
SSO Tabulation & Analysis Figure 1 shows the cumulative 10-42s by month for CY2012-20.
Figure 1 Reportable SSOs Page 8 of 21
Appendix 1 contains a list of every 10-42 and 10-48 event in CY2020. The table columns are grouped as follows:
1. The type, i.e., 10-42 or -48, is identified on the left. In one case a single event was both a 10-42 and a 10-48, as indicated.
2. Next to the right are the data included in the monthly SSO DMRs. It is noted that a "Reported Cause" is listed. This is typically based on the observations of the Operator that reported the SSO.
3. Next to the right is data determined by the Study Team: a. Cause b. Mitigation c. If Pretreatment follow-up is necessary
4. To the far right are follow-ups by NPDES Pretreatment a. FSEs visited b. Notice of Violation issued
The SSO Rate is defined as 100 times the number of SSOs in a year divided by the miles of sewer in the system. The Water Authority system has a total of approximately 2,414 miles of line (p. 8 of the Self-Assessment). The SSO rate is therefore 3.4, 3.0, 1.8, 2.2, 1.4, 1.7, 1.1, 1.1 and 0.7 for CY2012-20 respectively. Figure 2 shows the total sewer troubles, i.e. 10-40s, -42s, and -48s by year for CY2012-20. This graph does not include 10-48s due to "burps" which are not due to a blockage or other failure resulting in the overflow of sewage. Instead, air displaced during the Vactor jetting cleaning can under certain circumstances force out the water in the home fixture P-traps, e.g. toilets and sinks. These sometimes result in claims and are therefore included in the Property Damage totals for completeness and consistency. There was only one burp during CY 2020. This burp is identified in Appendix 1.
Page 9 of 21
Sewer Trouble in the Collection System Comparison CY12-20
250
200
192
183
150
122 106
100
72
50 45
16
14
0 CY 12 CY 13
157
139
136
120
103
71
67
68
54
44 40 35
24
15
17
14
114
88 81
96 72
50
27
26
17 11 7 7
CY 14 CY 15 CY 16 CY 17 CY 18 CY 19 CY 20
10-40 Backup 10-42 Overflow 10-48 Property Damage -Total Sewer Trouble
Figure 2 Sewer Trouble Comparison
Volume Spilled and Recovered Via the OERP, the Water Authority has implemented a policy of capturing spills and documenting actions. Appendix 1 provides the Ultimate Discharge Location for each reported SSO. Appendix 2 provides estimated spill volumes and volumes recovered for 17 reported SSOs for CY2020. Of the spill volume estimated not to be recovered, none was identified as directly reaching the Rio Grande. No spills reached a facility operated by the MRGCD. It was estimated that approximately 54% of the estimated spill volume was recovered in CY2020 as shown in Appendix 2.
Page 10 of 21
Actions Implemented and On-Going Programs
General Below are gaps that were identified in the CY2019 CMOM Report and were closed in CY2020, or are on-going programs, or both. In addition to the commitments made in the CMOM Report, in CY2020, the following additional actions were taken to expand the Water Authority's ability to operate and maintain the system.
1. Two new Vactors were obtained and put into service. 2. Interceptor manhole inspection was performed using a panoramic camera on 100
manholes in CY2020. In CY2021, approximately 260 additional manholes will be inspected. 3. The Water Authority's Corrective Maintenance Report now includes the distance from the downstream manhole to a blockage. 4. The Water Authority's Public Affairs section continued to support SSO prevention efforts and the FOG Policy in CY2020 by reprising an advertising campaign aimed at discouraging disposal of improper materials in household drains and planting trees near sewer lines. A news release ran for the Thanksgiving Day holiday. Appendix 3 displays the news release. In addition to the holiday release, the media campaign is still in place with ads on television, radio, outdoor boards, social media, and water bill inserts.
FOG Policy Implementation: The FOG Policy is an on-going program and FOG Enforcement efforts are a part of this program. Both the FOG Policy and the FOG Enforcement efforts are described above. On-going efforts are described in the FOG Enforcement section and not reiterated here.
The Water Authority has long had an FSE flier in English. An FSE flier was developed and implemented in CY2019 and a goal was set to develop an FSE flier in Chinese. However, it was determined that a Vietnamese flier was more prudent and this was developed in CY2020. The Water Authority has a three-year plan to distribute these fliers to all FSEs and continue to improve FOG inspections.
Overflow Emergency Response Plan (OERP) This is an on-going program to update the OERP as required. In CY2020, no modifications were made were made to the OERP.
The Collection Section is the "owner" of the OERP. The Collection Section creates the components of the OERP, routes for internal review (specifically including the Compliance Division), and the completed portions are approved for posting to SharePoint by the Collection Section Manager. Appendix 4 provides the OERP which was in effect at the end of CY2019. The most current version of the OERP is posted to http://www.abcwua.org/Sewer_System.aspx
Page 11 of 21
Closed Circuit Television (CCTV) This is an on-going program. The following recommendation is made in the FY2013 CMOM Report: "CCTV inspections of the collection system as follows: 1) Small diameter main lines less than 15": In four of five years, televise approximately 5% per year of the small diameter system. Televise high risk lines based on current Asset Management Plan and subsequent inhouse analysis. 2) Large diameter lines 15" and larger: Every fifth year, televise as much as possible acknowledging access limitations of the unlined concrete lines 15" and larger. Anticipated schedule: 3) FY2014-17: 5% of the small diameter each year. 2) FY18: Large diameter unlined concrete pipe." CMOM Report figures for cleaning and CCTV will continue showing fiscal year (FY) goals in accordance with funding and contracting cycles and actual metrics will reflect work through the end of the calendar year (CY). Figure 4 provides the CCTV goal for a ten-year basis and the actual CCTV inspection through CY2020. The CY2020 portion of this recommendation is complete. The CCTV program will continue. Anticipated schedule:
1. FY21: 5% of the small diameter. 2. FY22: 5% of the small diameter. 3. FY23: Large diameter unlined concrete pipe. 4. FY24: 5% of the small diameter. 5. FY25: 5% of the small diameter. 6. FY26: 5% of the small diameter.
Figure 3 Small Diameter Sewer CCTVed vs. Ten-Year Goal
Page 12 of 21
Cleaning Program Goal This is an on-going program. The following recommendation is made in the FY2013 CMOM Report: "The Water Authority will establish and monitor a goal of cleaning all gravity small diameter lines every ten years. (This will be accomplished through the existing Sub-Basin program.) The Water Authority will continue the program of high-frequency maintenance of known problem locations within the system. (This will be accomplished through the existing Short Interval program.) The frequency of Short Interval cleaning will vary in accordance with system performance and risk factors, maintenance history, and the latest maintenance findings." CMOM Report figures for cleaning and CCTV will continue showing fiscal year (FY) goals in accordance with funding and contracting cycles and actual metrics will reflect work through the end of the calendar year (CY). As shown Figure 5, the Water Authority is ahead of its goal to clean then entire system once in ten years through the Sub-Basin program. The Sub-Basin program and associated ten-year cleaning goal remain in place. While meeting this CMOM commitment for Sub-Basin cleaning, the Collection Section has increased Short Interval cleaning. The Water Authority is studying SSO rates in the Short Interval and the non-Short Interval portions of the Collection System. These studies are on-going and not yet complete. A possible outcome is a determination that total SSOs may be reduced by increasing the Short Interval cleaning per year and therefore decreasing the Sub-Basin cleaning per year. If so, the Water Authority would establish and monitor a different cleaning goal. This new goal would be established in a subsequent CMOM Annual Report.
Figure 4 Small Diameter Sewer Cleaned vs. Ten-Year Goal Page 13 of 21
Force Main Inspection Program This is an on-going program in which the alignment is annually inspected for all force mains and valves found in field are compared to those in the GIS mapping and this information is stored in Maximo.
Lift Station 20 pumps westside flow to the Southside Water Reclamation Plant (SWRP) via twin 30" ductile iron force mains. Per the CY2019 CMOM report, an air pocket profile was completed using a smart ball on the north force main in CY2020. A report was received and from development of this air pocket profile, air release valves (ARVs) were identified for replacement or relocation in coordination with the SWRP. In CY2021, the Water Authority will install replacement ARVs and then perform additional smart ball tests on both force mains.
Root Foaming The following recommendation is made in the FY2013 CMOM Report: "Starting in FY15, implement a 3-year pilot program. Root foam selected lines that meet the root infested and / or inaccessibility criteria. Compare effectiveness to mechanical cleaning currently practiced and provide recommendation."
The Root Foaming Pilot Project is a three-year treatment program with follow-up study. The FY15 and FY16 groups were foamed in June 2015 and March 2016 respectively. Per vendor recommendations, the FY15 group was retreated in June 2017. This completed the foaming application portion of the Pilot Project. An interim inspection of the FY15 treated and control group was performed in FY2016 and was inconclusive. During FY2017, the FY15 and FY16 lines, both treated and control, were scheduled for CCTV inspection. In CY2018, this CCTV data was examined to compare treated and control pipes but was inconclusive. In CY2019, the review continued.
In CY2020, the final report for the Root Foaming Pilot project was completed. The report concluded that a root foaming program should not be implemented. Instead, efforts should be focused on existing cleaning programs specifically evaluating the effectiveness of the Short Interval program (frequency, selected lines, time of year, etc.).
Odor Complaints Odor complaints are tabulated and reported monthly. The Water Authority odor control program is described in the CMOM Self-Assessment Report in the Hydrogen Sulfide Monitoring and Control (HSMC) section in the current CMOM Program Self-Assessment. Portable odor control carbon units were implemented in CY2020.
Page 14 of 21
Identified Gaps in the Water Authority Processes with Recommendation to Close
In the process of continuous improvement, the Water Authority is committed to identifying and closing gaps. As discussed above, most of these recommendations are now considered On-Going programs. Prohibited Discharges, i.e., SSOs The Water Authority acknowledges that prohibited discharges have occurred and that all discharges from the sanitary sewer system are prohibited. Recommendation: The Water Authority will annually examine sewer system performance, set specific steps for decreasing SSOs and mitigating their impacts, and has a program of continuous improvement.
Page 15 of 21
Appendices
Page 16 of 21
Appendix 1
Sanitary Sewer Overflow Analysis Table
Page 17 of 21
10-42 10-48 10-42 &10-48 Cause Mitigation Pretreatment Follow Up Requested FSEs Visited Notice of Violation
Type
X X X X X
X X X
X X X
X X X X X X
X X X X X
X X
DMR
Maximo WO #
Diameter
Repeat
Repeat within 1
year
Date of SSO
Time of Duration SSO (HH:MM)
Location
Estimated Volume (gallons)
732025
8
N
N
1/6/2020 12:01 PM 3:14
5010 ALAMEDA BLVD NE
NA
732110
10
Y
N
1/6/2020 4:00 PM 4:30
3401 SMITH AVE SE
NA
741697
8
N
N
1/12/2020 11:28 AM 1:52
5601 JEFFERSON ST NE
5,600
749443
8
N
N
1/17/2020 11:00 AM :35
4825 ISLETA BLVD SW
4,326
776513
8
N
N
2/6/2020 11:53 AM :30
701 DON CIPRIANO CT NE
NA
784233
8
Y
N
2/12/2020 6:11 PM
:34
1209 RICHMOND DE SE
3,400
810255
8
N
N
2/27/2020 3:31 PM
:34
2501 PHOENIX AVE NE
1,700
813434
36
N
N
2/29/2020 3:14 PM 2:10
227 JOHN ST SE
3,250
834267
8
Y
N
3/10/2020 6:26 PM
:41
312 WELLESLEY DE SE
NA
837705
8
N
N
3/12/2020 9:47 AM :48
8716 RANCHER RD SW
48
856480
8
N
N
3/24/2020 2:24 PM
:36
1300 CUATRO CERROS TRL SE
60
865633
8
Y
N
3/30/2020 7:05 AM 2:30
1418 CENTRAL AVE SE
NA
869146
8
N
N
4/1/2020 11:51 AM :29
1700 LOMAS BLVD NE
725
902511
24
N
N
4/18/2020 4:30 PM 1:10
1025 BROADWAY BLVD SE
350
921719
8
Y
Y
4/30/2020 8:10 AM :30
4501 JUAN TABO BLVD NE
300
923989
8
Y
N
5/1/2020 1:39 PM
:36
700 SAGEWOOD CT SE
900
1013555
8
N
N
6/16/2020 10:19 AM :41
2101 LOUISIANA BLVD NE
75
1073425
8
N
N
6/24/2020 11:26 AM 1:00
1233 COLUMBIA DR NE
NA
1041311
8
N
N
6/27/2020 11:23 PM 3:07
RUNNING BEAR AVE SE & WHITE DOVE ST SE
935
1259702
8
N
N
10/6/2020 12:31 PM :59
5022 ARROYO CHAMISA RD NE
1,475
1274518
30
N
N 10/12/2020 11:28 AM :02
4300 PROSPECT AVE NE
100
1373373
12
N
N 11/26/2020 3:29 PM 1:21
425 LOUISIANA BLVD SE
25
1376051
3
N
N 11/29/2020 11:00 AM 4:15
1026 WESTERN MEADOWS CT NW
NA
1394696
2
N
N 12/16/2020 11:53 AM 1:07
5551 MIDWAY PARK PL NE
100
Reported Cause of Overflow
LF GR/RGS GR/RGS
CO RGS GR RGS GR RGS/ RT CU RGS/RT GR GR/RGS GR/RGS RGR RGS/RT GR BP
V GR CO RGS EQ LF
SSO Team Study
Observed Environment
Impacts
Action Taken
Ultimate Discharge Location
Volume Recovered (gallons)
NA NA NEAH NEAH NA NEAH NEAH NEAH NA NEAH NEAH NA NEAH NEAH NEAH NEAH NEAH NA NEAH NEAH NEAH NEAH NA NEAH
CC
NA
CC
NA
CC/HTH/CWW/RCS/WD
SD
HTH/CWW/RP/WD
YD
CC
NA
CC/HTH/PO/CWW/WD
SD
CC/HTH/CWW/RP/WD
PST
CC/HTH/ CWW/WD
PST
CC
NA
CC/HTH/IN/PO/CWW/WD
PST
CC/HTH/RS/WD
PST
CC
NA
CC/HTH/CWW/WD
PST
CC/HTH/CWW/RP/RS/WD
PST
CC/HTH/RP/WD
PST
CC/HTH/BR/RP/WD
PST
CC/HTH/RP/RS/WD
PL
IN
NA
CC/HTH
PST
CC/HTH/CWW/RS/WD
AC
HTH/RP/RS/WD
AC
CC/HTH/CWW/WD
PST
ET/T
NA
HTH/RP/WD
PST
NA NA
5,600 1,200 NA 1,000
700 1,000 NA
30 50 NA 725 350 300 800 50 NA 1,475 100 25 NA 100
LF SL GR CO SL LF DB CO RT CO RT GR/SL GR/RGS GR/RGS LF RT GR BP V RGR CO CO EQ LF
RH SI/SP PT/SI NF
SI RH SC RH SI/SP NF SI/SP RH PT SI/RH RH RH RH SP NF SI NF RH REP REP
Enforcement
x
7
1
x
2
2
x
4
4
Appendix 2
Sanitary Sewer Overflow Volume Captured Analysis Table
Page 18 of 21
Maximo WO Date of SSO #
741697 1/12/2020 749443 1/17/2020 7844233 2/12/2020 810255 2/27/2020 813434 2/29/2020 837705 3/12/2020 856480 3/24/2020 869146 4/1/2020 902511 4/18/2020 921719 4/30/2020 923989 5/1/2020 1013555 6/16/2020 1041311 6/27/2020 1259702 10/6/2020 1274518 10/12/2020 1373373 11/26/2020 1394696 12/16/2020 Grand Total
CY2020 10-42 SPILL VOLUME AND VOLUME RECOVERED
Estimated
Volume
Location
Volume
Recovered
(gallons)
(gallons)
5601 JEFFERSON ST NE 4825 ISLETA BLVD SW 1209 RICHMOND DE SE 2501 PHOENIX AVE NE
227 JOHN ST SE 8716 RANCHER RD SW 1300 CUATRO CERROS TRL SE 1700 LOMAS BLVD NE 1025 BROADWAY BLVD SE 4501 JUAN TABO BLVD NE 700 SAGEWOOD CT SE 2101 LOUISIANA BLVD NE RUNNING BEAR AVE SE & WHITE DOVE ST SE 5022 ARROYO CHAMISA RD NE 4300 PROSPECT AVE NE 425 LOUISIANA BLVD SE 5551 MIDWAY PARK PL NE
5,600 4,326 3,400 1,700 3,250
48 60 725 350 300 900 75 935 1475 100 25 100 21,594
5,600 1,200 1,000
700 1,000
30 50 725 350 300 800 50 1475 100 25 100 11,755
Volume Not Recovered
3,126 2,400 1,000 2,250
18 10 100 25 935 9,864
% Recovered
100% 28% 29% 41% 31% 63% 83%
100% 100% 100%
89% 67%
0% 100% 100% 100% 100% 54%
Appendix 3
Thanksgiving Day News Release
Page 19 of 21
NEWS RELEASE In Time for Thanksgiving: Water Authority Resumes its War on Grease
________________________________________________________ Contact: David Morris, 264-5691
ALBUQUERQUE, November 17 - Just in time for Thanksgiving, the Water Authority has re-launched its PSA campaign to remind customers not to dispose of cooking grease in the sewer system. Billboards and TV and radio spots resurrect last year's "spokes-elephant," who points out that it makes as much sense to put a pachyderm down the sink as it does to pour grease down the drain.
FOG - Fats, Oils, and Grease - is a leading cause of sewer overflows, which in turn can cause thousands of dollars in property damage and create a public health threat. Water Authority customers are asked to do their part to prevent costly and hazardous sewer overflows:
1) Dispose of cooking grease in the trash, not the sink. Kitchen grease should be poured into a can or milk carton or soaked up with a paper towel and thrown into the garbage for disposal at the landfill. Otherwise it can collect and harden in the sewer system. For the same reason, greasy food scraps should be thrown away, not put in the garbage disposer. Remember: Cool it, Can it, Chuck it!
2) Don't put rags or disposable wipes down the sink or toilet. Rags of any sort--even ones advertising themselves as "flushable"--can cause sewer blockages, especially if they get caught on tree roots. Rags and disposable wipes should be thrown into the garbage for disposal at the landfill.
3) Plant trees well away from sewer lines. Roots grow toward breaks and cracks in sewer lines in search of water. Once they've penetrated a pipe, the roots can cause blockages leading to sewer overflows.
Appendix 4
Overflow Emergency Response Plan (OERP)
Page 20 of 21
Overflow Emergency Response Plan
Albuquerque Bernalillo County Water Utility Authority
Customer calls dispatch with issue
Dispatch collects data and creates
a Service Request; Task
elevated to supervisor
Note: All Emergency responses are initiated by a call to Dispatch at 842WATR (842-9287). Please call there
first. If you do not, the emergency responders have to call and delay the
resp onse
Collection Response
Follow up study and mitigation.
Pg. 6
Notification process. Pg. 7
Alert Media. Pg. 10
12-1-2019
Applies only to Collection System sewer problems.
Supervisor creates a work order and sends crew to
location. Status of work order is updated to DISPATCHED
Spill to pervious areas.
Pg. 3
Spill entered / entering storm drain collection system. Pg. 4
Private vs. public SSO.
Pg. 5
Spill has entered storm pump station.
Pg. 9
Spill entering Waterway.
Pg. 11
Unblock and Clean up. Pg. 2
Tech confirms asset and fills out required
information in the work order
Supervisor reviews work order for quality assurance.
Status of work order is updated to COMPLETE AND
READY FOR REVIEW
Planner / Scheduler does quality control and updates
status of work order to COMPLETE
Page 1
Overflow Emergency Response Plan
Albuquerque Bernalillo County Water Utility Authority
12-1-2019
Unblock and Clean Up. Pg. 1
Crew arrives on site
Clean Sewer. Pg. 5
Is SSO clearly public?
No
Note the time Yes of dispatch and
arrival on scene
Private vs. Public SSOs.
Pg. 5
Investigate the cause and stop the
sanitary sewer overflow.
Protect public from area.
Note the start and stop time that the overflow occurred
Apply HTH per SOP
If evidence of "Extreme" FOG.
Is additional help necessary to aid the clean up / remediation
efforts?
The Vactor truck(s) Yes should be
dispatched immediately.
No
Pretreatment Involv em ent .
Pg. 8
Remove spill from surface. Remove any solids. Wash down spill area and remove wash water.
Determine whether overflow has entered pervious area, storm drain, ditch, canal, or storm pump station.
Spill has entered a waterway.
Pg. 11
Spill to pervious area.
Pg. 3
Spill entered / entering storm drain collection system. Pg. 4
Spill has entered a COA storm pump station. Pg. 9
Page 2
Overflow Emergency Response Plan
Albuquerque Bernalillo County Water Utility Authority
Spill to pervious area. Pg. 2
Immediately begin collecting spill with
Vactor truck.
When SSO stopped, apply washwater & HTH to spill area &
allow to flow to pervious area and remove washwater.
Supervisor or Superintendent to
determine / recommend rem e diati on. Consult with Chief Engineer if required.
Yes
Supervisor or
Superintendent to
determine if public
No
access to pervious
area is a concern.
Implement Allow to dry.
Remediation Complete. Pg. 1
12-1-2019 Page 3
Overflow Emergency Response Plan
Albuquerque Bernalillo County Water Utility Authority
Spill entered / entering storm drain collection system. Pg. 2
If possible, position 2nd Vactor to
remove spill prior to reaching inlet.
Determine how far downstream the spill has reached.
12-1-2019
SSO Reaches AMAFCA Facility
Name Jerry Lovato*
Bernalillo County Facility Patrick E. Chavez#
Contact Position Executive Engineer
Storm Drainage Maintenance Manager
Office 884-2215
848-1505
NMDOT Facility COA Facility
Thomas Kratochvil District 3: Assistant District Engineer-Maintenance
Kathy Verhage **
Senior Engineer
N/A 768-2778
Cell 362-0020 934-2704
228-8169 803-8058
Add wash water & remove at downstream manhole. Remove immediately if rain is imminent. If not, remove
next normal work day.
Wash water to street and inlet.
SSO Reaches COA storm drain.
Assist in clean up as requested.
Remediation Complete. Pg. 1
Note: Process shown is for typical spills. Spills that are not appropriate for Vactor removal may require a joint response with the impacted MS4 Permittee in which the spill is captured, treated, and determined appropriate for release.
*If Jerry Lovato is not immediately available, call:
Nolan Bennett: Field Engineer (505) 301-6941 Sal Hernandez: Superintendent (505) 366-8209
**If Kathy Verhage is not immediately available, call:
David Harrison: Engr. Div. Manager (505) 238-4158 Carl Rinkenberger: O&M Manager (505) 250-4334 Daniel Tapia: O&M Supt (505) 228-6874
#If Patrick E. Chavez is not immediately available, call: Kali Bronson: Stormwater Program Compliance Manager (505) 401-1779
Page 4
Overflow Emergency Response Plan
Albuquerque Bernalillo County Water Utility Authority
Private vs. Public SSOs.
Pg. 2
12-1-2019
Ask Supervisor.
City of Albuquerque Code Enforcement (505) 924-3450
Bernalillo County Natural Resource Services Review & Permitting Section
(505) 314-0375
Village of Los Ranchos (505) 344-6582
Code Enforcement office
NMED Liquid Waste Program (505) 222-9500
(505) 827-1840
For non-Authority spills in the County, in addition to calling Natural Resources Services, contact Patrick E. Chavez at 934-2704. For any nonAuthority that impact an AMAFCA or NMDOT
facility, alert the appropriate contact listed on page 4.
For non-Authority spills in the City limits, in addition to calling the appropriate portion of COA
Code Enforcement, also alert: Kathy Verhage - (505) 803-8058
Clearly Public?
No
Clearly Private?
No
Elevate to
Superintendent.
Yes Resolve if Yes
Public?
Yes
Inform Public
No
Clean Sewer. Pg. 2
Do not clean sewer
Depending on jurisdiction, follow up with City of
Albuquerque, Bernalillo County, Village of Las Ranchos or NMED
(See table for contacts)
Remediation Complete. Pg. 1
Note: The identified code enforcement contacts will also be utilized to report private service lines issues resulting in sewage spills to private or public property.
Public and private lines may be differentiated on the Water Authority GIS Mapping.
Private lines that may be confused with Water Authority mains should be identified to the Collection Section Research Analyst for inclusion in the "Waste Water NonAuthority" layer.
Page 5
Overflow Emergency Response Plan
Albuquerque Bernalillo County Water Utility Authority
Follow up study and mitigation.
Pg. 1
12-1-2019
*If the defect is due to corroded concrete, rehab of the manhole to manhole pipe segment is typically forwarded directly to
Centralized Engineering for assignment to an On-Call contractor or inclusion in planned rehab project. If the defect is in a VCP line, Assistant Superintendent/ Gravity Superintendent/ Construction Supervisor will make the determination.
Research Analyst/GIS Intern creates a follow-up cleaning
and CCTV work orders for gravity 10-40s, -42s, and 48s.
Sewer line is televised.
Research Analyst compiles maps and data associated with all unstudied 10-42s and 48s for SSO Study
Team Meeting.
SSO Team examine/
request more data/
No
reso lve.
Consensus cause. Consensus mitigation.
Is a defect
Will it be assigned
Forward to Centralized Engineering and copy
identified as Grade
Yes
in-house or to on-
On-Cal l
Collection Section Manager, Gravity
7 or 8?
call contractor?*
Superintendent, and Research Analyst.
No
Research Analyst studies SSOs. Obvious cause?
In -Hous e Create Maximo
Work Order. Yes
Research Analyst compiles SSO cause
and mitigation
Consent List SSO Team accepts/
requests further study
Accepted Cause. Accepted Mitigation.
Compile data in SSO Analysis Table for inclusion in CMOM Report.
Review with Collection Section Manager for suggestions and approval.
Non-FOG
Collection Section Manager approves and routes for implementation.*
Mitigation
FOG
End of Pretreatment involvement.
Pg. 8
Submit to Pretreatment for
enforcement. Pg. 8
SSO Tracking Table
Page 6
Overflow Emergency Response Plan
Albuquerque Bernalillo County Water Utility Authority
Notification Process. Pg. 1
Document but do not report.
No Reporting Yes
No
For system breaks resulting in release on KAFB: Call
Kirtland AFB Command Post at (505) 846-3777 within 12
hours.
For spills on the UNM Main and North Campus contact the Work Control Center (M-F 7:00 a.m. to 4:30 p.m.) at (505) 277-1600 and all other times contact the Campus Police at (505) 277-2241.
Spill from WUA System?
Yes No
Spill contained in
WUA Facility (e.g. dry
No
well)?
Spill results from contractor's work or construction activity
(Section 911).
Yes
Contractor verbally reports to collection
section Superintendent or standby Supervisor.
Contractor provides 24 hour written report.
EPA DMR, 15th of the month
Compliance Division
DMR Collection Section SSOs
12-1-2019
Yes
Spill contained in private facility (e.g.
basement SSO)?
No
GWQB Reporting Ponded sewage on a pervious area may require additional reporting to the Ground Water Quality Bureau (GWQB). Circumstances presumed to require this reporting will be: 1. A sewage spill that: a. Is ponded for more than 24 hours and, b. At a depth of more than 12 inches over an area of more than 0.1 acre. The normal 24-hour call to NMED Surface Water is presumed to meet the requirement for a 24-hour notification to the GWQB. The Collection Section Manager shall be notified and shall be responsible for preparing the following additional reporting: 1. One week written report. Presumed the same as the five day report provided to NMED Surface Water. 2. 15-day Corrective Action Report.
O & M Supervisor Reports
Within 24 hrs. of time of
dispatch notified or contractor verbally reports
Assistant Superintendent prepares written
report. Field Division Manager
signs.
Within 5 days
Oral report NM Environment Dept. Email report EPA POI
Written Report EPA NM Environment
Department Pueblo of Isleta
Collection Section Manager to COA &
AMAFCA
Note: This page shows Oral and Written Reports for "typical" SSOs. See page 11 for reports of "Category One" SSOs.
Page 7
Overflow Emergency Response Plan
Albuquerque Bernalillo County Water Utility Authority
Pretreatment Involv em ent .
Pg. 2
Submit to Pretreatment for
enforcement. Pg. 6
12-1-2019
Supervisor calls Pretreatment Office Assistant (289-3419)
o Address o Date o Time o Supervisor Name o Estimated Volume
Is P2 spec. available?
Yes P2 spec. investigates
Proceed to SSO Location
No
Pretreatment Engineer
Investigates
Observe site, fill out form, take pictures, and collect sample if
possi ble
Use mapping resources to establish upstream basin area
Develop list of FSEs in area
Note any problem FSEs.
LINKO Generated Notice of Violation
(NOV)
Start Enforcement Yes Process
Is a FSE resp onsible?
No
Update SSO Tracking Table.
Pg. 6
Visit FSEs and check GRSs and manifests
Page 8
Overflow Emergency Response Plan
Albuquerque Bernalillo County Water Utility Authority
Spill has entered a COA storm pump station. Pg. 2
Shut down pumps
Remove sewage with Vactor or pump
to SAS
Wash down wet well and remove wash water
Remediation Complete. Pg. 1
Note: Process shown is for typical spills. Some spills may require a joint response with the City of Albuquerque in which the spill is captured, treated, and determined appropriate for release.
12-1-2019 Page 9
Overflow Emergency Response Plan
Albuquerque Bernalillo County Water Utility Authority
Alert Media. Pg. 1
For large or significant spills.
Superintendent, Chief Engineer, or Division Manager to contact Public Affairs Manager (PAM), Dave Morris, or Chief Operating Officer
(COO), John Stomp. Provide required information.
Media alerted by PAM, COO, or designee
12-1-2019
Page 10
Overflow Emergency Response Plan
Albuquerque Bernalillo County Water Utility Authority
Spill has entered a waterway.
Pg. 2
No Reaches Rio Grande?
If possible, stop the
No
flow from entering
Reaches MRGCD
the waterway and
Facility?
collect wastewater.
Yes
Contact (In sequence until contacted)
Jason Casuga Engineering
(505) 259-1005
Joe Brem
ABQ Division Manager
(505) 249-5780
Mike Hamman CEO / Chief Engineer
(505) 206-6378
Pg. 12 Sample MRGCD facility
for E. coli upstream and downstream of SSO.
12-1-2019
No Remove debris.
Yes Pg. 1
Is spill fully contained?
Yes Assist in
cleanup as requested.
No
Category One SSO
Immediately following the overflow event, contact the following numbers until a live person is reached. In the event there is no answer, leave a message on each number.
Position
POI Category One Protocol Co nt ac ts
Name
Cell Number
Office Number
Emergency Dispatch
N/A
N/A
(505) 869-3030
Environment Division M an ager
Ruben Lucero (505) 917-8346 (505) 869-9819
Transportation Division M an ager
James Weldo n
(505) 933-1225 or
(505) 417-0124
(505) 869-9818
Water Quality Specialist Cody Walker (505) 220-4595 (505) 869-9623
Page 11
Overflow Emergency Response Plan
Albuquerque Bernalillo County Water Utility Authority
Pg. 11 Sample MRGCD facility for E. coli upstream and downstream of SSO.
12-1-2019
Contact NPDES Program Manager
(505) 274-0271 cell
Pretreatment Sampling Staff Meet On-Site
Agree on Sampling Location in Coordination with Collection Section
and/or MRGCD Staff
Obtain Sample Upstream and Downstream of SSO
Transport to SWRP Water Quality Lab
Test per E. coli Method SM9223-B-2004
or Other Approved EPA Meth od
Provide Results to Collection Section
Manager
Page 12
Appendix 5
Goal Summary - CY2020 Report
Page 21 of 21
Goal Summary - CY2020 CMOM Report
Goal
Timing
CCTV all gravity pipes suffering a blockage. For all SSOs, determine a cause and mitigation and report in the next
CMOM report
Annually
Interceptor manhole inspection for an additional 260 manholes
CY2021
Public advertising
Distribute FSE fliers in all languages and improve FOG inspections
On-Going CY2023
Update OERP
As required
Page # for Discussion
6
11 11 11
12
CCTV a portion of system
Ten Year goal.
Report
13
annually.
Ten Year goal.
Clean a portion of the system
Report
14
annually.
Force main inspection program
Annually
15
Perform an air pocket profile, utilizing a smart ball, of Lift
Station 20's north and south force main. Install replacement CY2021
15
ARVs on north and south force main.
SSOs: Decrease number and mitigate impact
On-Going
16
CMOM Annual Report 2021
Contents
Capacity, Management, Operations and Maintenance (CMOM) Plan Overview............................2 Report Purpose ..............................................................................................................................2 Permit Requirements ....................................................................................................................3 CMOM Program Self-Assessment ................................................................................................3
FOG Policy .......................................................................................................................................4 FOG Enforcement..........................................................................................................................5
SSO Analyses....................................................................................................................................6 Permit Requirements ....................................................................................................................6 SSO Study Team ..........................................................................................................................6 Table 1 Sewer Trouble Definitions...............................................................................................7 Causes & Mitigations ...................................................................................................................8 SSO Tabulation & Analysis .........................................................................................................9 Volume Spilled and Recovered ..................................................................................................11
Actions Implemented and On-Going Programs .............................................................................12 General .......................................................................................................................................12 FOG Policy Implementation ........................................................................................................13 Overflow Emergency Response Plan (OERP) ...........................................................................13 Closed Circuit Television (CCTV).............................................................................................14 Cleaning Program Goal ..............................................................................................................15 Force Main Inspection Program .................................................................................................16 Odor Complaints.........................................................................................................................16
Identified Gaps in the Water Authority Processes with Recommendation to Close......................17 Prohibited Discharges, i.e., SSOs ...............................................................................................17
Appendices .....................................................................................................................................18 Appendix 1 Sanitary Sewer Overflow Analysis Table ...........................................................19 Appendix 2 Sanitary Sewer Overflow Volume Captured Analysis Table ..............................21 Appendix 3 FOG Advertising Campaign ................................................................................22 Appendix 4 Overflow Emergency Response Plan (OERP) ....................................................25 Appendix 5 Goal Summary - CY2021 Report ........................................................................26
Page 1 of 26
Capacity, Management, Operations and Maintenance (CMOM) Plan Overview
In accordance with National Pollutant Discharge Elimination System (NPDES) Permit No. NM0022250 (Permit), the Albuquerque Bernalillo County Water Utility Authority (Water Authority) prepared this Capacity, Management, Operations and Maintenance (CMOM) Plan. The Permit was renewed in CY2019 with an effective date of December 1, 2019. The CMOM Plan consists of the following documents:
1. FOG Policy 2. CMOM Annual Report 3. CMOM Program Self-Assessment The CY2021 CMOM Annual Report follows previous FY2013-17 and CY2017-20 reports. The previous reports, as well as the most recent, can be accessed at https://www.abcwua.org/sewersystem-overview/. Appendix 5 provides a summary of goals established in this CY2021 CMOM Report. Report Purpose As indicated by its name, the CMOM Annual Report will be reissued to describe CMOM activities in the previous calendar year (January 1 to December 31). The CMOM Annual Report provides summary descriptions of CMOM activities (past and planned) and is intended to be a communication tool. The report is intended for Water Authority staff, regulatory authorities, customers, and the general public.
Page 2 of 26
Permit Requirements The Water Authority discharges to the Rio Grande under authority of NPDES Permit No. NM0022250 (Permit). Under this Permit, the Water Authority operates the Southside Water Reclamation Plant (SWRP) and the Collection System. The Permit was renewed effective December 1, 2019. The following are the Permit requirements that impact the collection system.
1. The Water Authority shall report all overflows with a (monthly) Discharge Monitoring Report (DMR). (Part I, Paragraph D).
2. Overflow reporting requirements were unchanged for EPA and NMED. (Part I, Paragraph D).
3. Overflow reporting requirements were modified for spills impacting the Pueblo of Isleta (POI) were modified in accordance with the "Pueblo of Isleta Reporting Requirement" which were a subsection of the renewed Permit. (Part I, Paragraph D and "Pueblo of Isleta Reporting Requirement".)
4. The Water Authority shall continue to implement and update (if necessary) the CMOM plan. (Part II, Paragraph E.)
The full permit is available at https://cloud.env.nm.gov/water/pages/view.php?ref=6881&k=fd428af5b1 CMOM Program Self-Assessment EPA states (see https://mwrd.org/sites/default/files/documents/USEPA_3-cmomselfreview.pdf): "An important component of a successful CMOM program is to periodically collect information on current systems and activities and develop a "snapshot-in-time" analysis. From this analysis, the utility establishes its performance goals and plans its CMOM program activities." The Water Authority developed Self-Assessments as a part of the FY2013 and FY2014 reports. Because the data provided in the Self-Assessment does not significantly change year-to-year, the Water Authority has set a goal of updating the Self-Assessment every five years.
Therefore, the CMOM Program Self-Assessment CY2018 has been prepared and posted to https://www.abcwua.org/sewer-system-overview/ along with the CMOM Reports. Rather than being an appendix to the CMOM Report, it is now a stand-alone document.
The next update will coincide with the CY2023 CMOM Report.
Page 3 of 26
FOG Policy
The Water Authority's FOG Policy is a separate document. The FOG Policy was developed as a requirement of the NPDES Permit effective on October 1, 2012 and subsequently approved by the United States Environmental Protection Agency (EPA). The policy was developed to work in conjunction with the Water Authority Sewer Use and Wastewater Control Ordinance (SUO) and Enforcement Response Plan (ERP) to reduce the rate of SSOs in the collection system and decrease FOG loading at the SWRP. The policy describes expectations for FOG dischargers such as Food Service Establishments (FSEs) and waste haulers, and the steps the Water Authority is taking to mitigate FOG.
The new NPDES Permit was effective December 01, 2019, allowing for an update to the Industrial Pretreatment Program. This update started with an amendment to the SUO, board approved on July 05, 2021. This amendment updated the FOG section to include solids and standardize the terminology to match plumbing code and industry standards and include Hydromechanical Grease Interceptor exclusions to the 25% rule. Fats, Oils, and Grease (FOG) is now Fats Oils, Grease and Solids (FOGS). Grease Removal Systems (GRS) are now referred to as Grease Interceptors (GI). HGIs being more efficient GIs are allowed to hold up to 50% grease and solids. The FOGS Policy and ERP are currently under revision to reflect SUO changes and bolster both documents.
The FOG Policy sets a Water Authority goal of inspecting every FSE at least once every three years. Details of what is expected of the FSE in terms of Grease Removal System (GRS) functionality, pumping schedule, maintenance, and recordkeeping are identified. The FOG policy explains the Water Authority use of the 25% solids and grease rule (25 Percent Rule) to determine if a GRS is filled to capacity. The policy also contains Best Management Practices (BMPs) such as scraping plates, using screens, and not using emulsifiers, etc.
Pumper requirements are also covered in the FOG Policy. Full evacuation of a GRS is required each time pumping occurs. The pumper must leave the FSE documentation in the form of manifests that contain pertinent information such as date, time, volume pumped, and the condition of the GRS. The FOG Policy lists the minimum service to be provided by the pumper.
Enforcement of FOG violations and hauled wastewater violations is described in the FOG Policy. The FOG Policy works in conjunction with the ERP to set administrative assessments for violations.
The FOG Policy also sets forth the process for identifying new sources of FOG. The Water Authority Pretreatment Program will update the FOG database on an annual basis. The FOG Policy sets a goal that the Water Authority will meet with the City of Albuquerque, Bernalillo County, the Village of Los Ranchos, the Village of Corrales, plumbers, and the New Mexico Restaurant Association on a periodic basis to discuss FOG issues.
In developing the FOG Policy, the Water Authority held a meeting with the hauled wastewater permit holders on July 22, 2013 and a public meeting on July 25, 2013 to discuss the proposed Policy. The final FOG Policy was submitted to the EPA on September 27, 2013 and updated in the Pretreatment Program modification documents sent to EPA on June 2, 2014. No comments from EPA were received regarding either submission, thus indicating approval. The Sewer Use and Wastewater Control Ordinance was updated and approved by the Board in July 2021. The Pretreatment Program documents including the FOGS and Enforcement Policies have been
Page 4 of 26
revised to match the Ordinance updates and are expected to be submitted to EPA for approval once the legal review is complete, by December 2022. FOG Enforcement In CY2021, the Water Authority Pretreatment Program had 1,718 compliant FSEs out of 2,135 FSE sites for a compliance rate of 80%. Three hundred-sixty-seven (367) FSE inspections were conducted with 222 passing, and 145 failing. Of the 145 failed inspections, 77 Notices of Violation were issued. Thirty-three (33) of the 77 violations were resolved and the remainder are outstanding. In response to SSOs, twelve (12) FSE inspections were conducted with five (5) passing and seven (7) failing. Of the seven (7) failed inspections, zero (0) Notice of Violations were issued and all were corrected before issuance of violations. In addition, Water Authority Pretreatment personnel distributed FOG brochures to FSEs, singlefamily residences and apartment complexes upstream of the SSOs. Additionally, the Water Authority's Public Information Office advanced radio, print and television public outreach for the purpose of improving the Water Authority's FOG Policy.
Page 5 of 26
SSO Analyses
Permit Requirements The Permit requires a CMOM Plan. The Plan goal is to reduce SSOs. The FOG Policy states that the Pretreatment Program will investigate all SSOs related to large amounts of grease. The policy is to take enforcement actions for violations of FOG requirements with priority on FSEs causing repeat SSOs. SSO Study Team To meet these requirements, the Water Authority created an SSO Study Team. The Team is comprised of:
1. Collection Section - Research Analyst (team lead), Gravity Superintendent, Assistant Superintendent and Closed Circuit Television (CCTV) Supervisor;
2. NPDES Pretreatment -Industrial Pretreatment Engineer and Pollution Prevention Specialist.
The Mission Statement for the Study Team is: The SSO Study Team will work inter-divisionally to study, analyze and determine causes of previous SSOs to mitigate future SSOs in the Collection System. The Study Team procedure is:
1. Tabulate all 10-40s, 10-42s and 10-48s (see Table 1 for definitions). 2. Ensure all segments responsible for causing 10-42s and 10-48s are televised. 3. The Research Analyst will review and analyze all CCTV inspections to determine
causes (if possible) and document findings. 4. To conduct meetings with the SSO Study Team to review and analyze CCTV that
needs further investigation for resolution. 5. Recommend/implement and document mitigations (if possible) based on analysis. 6. Coordinate with NPDES Pretreatment concerning grease issues discovered during
analysis.
Page 6 of 26
10-40 10-42 10-48
Sewer Backup SSO Reportable
Table 1 Sewer Trouble Definitions
Sewer Trouble Definitions
A gravity line blockage that does not result in a spill, or in the vacuum system, a low vacuum (low vac) that causes a customer service disruption. Does not result in an SSO Reportable (10-42) or a Property Damage (10-48). An overflow of sewage from the system that may impact surface waters. These are reported to the EPA and other locally impacted stakeholders.
Property Damage
An overflow of sewage from the system that results in damage to private property. These are not reportable under current definitions.
Appendix 1 identifies all 10-42s and 10-48s, and the overflows that resulted in both a 10-42 and a 10-48. When documenting the number of Sewer Troubles of different types, for example in Figure 1 and Figure 2, the 10-42 item includes all overflows that may impact surface waters, including those that also had property damage; the 10-48 item includes overflows that only resulted in property damage. This prevents double-counting the number of overflow occurrences.
All 10-40s, 42s and 48s were CCTV inspected, although only 10-42s are "reportable", i.e., required to be reported to the EPA, et al. All 10-42s and 48s were then examined by the Study Team and a Cause and Mitigation were determined.
Table 2 Types of Causes for SSOs
Cause(s) of SSO from DMR
CO - Construction
DB - Debris
CU-Cause Unknown RK-Rocks
EQ - Equipment
GR -
Failure
Grease
SGG-Sand, grit or
gravel
RT - Roots
RN -
LF - Line Failure
Rainfall
V - Vandalism
RGS-Rags
RGR - Roots / Grease BP-Burped
Causes determined from CCTV SC - Surcharged SL - Sag in Line
IT - Intruding Tap
MH - Manhole
OJ - Offset Joint
Page 7 of 26
Causes & Mitigations
The Cause(s) were selected from Table 2 that identifies SSO causes from the DMR and CCTV. The monthly SSO DMR has a specific list of Causes that are based on system observations made by an Operator or Supervisor at the site of an SSO. The CCTV data provided to the Study Team often results in a different, more refined Cause or Causes. Table 3 provides the causes determined by the Study team for CY2021. (Note: Percentages may not add up to 100%, as they are rounded to the nearest percent.)
Table 3 Summary of Causes from SSO Study
10-42,10-48 Causes Burp Construction Debris Grease Grease/Rags Grease/Sag in Line Line Failure Manhole Roots/Grease Roots Sag in Line Vandalism Equipment Failure Grand Total
Total 2 0 0 2 2 0 1 1 1 4 2 1 2 18
% of Total 11% 0% 0% 11% 11% 0% 6% 6% 6% 22% 11% 6% 11%
100%
Mitigations are the steps that the Team identified to prevent a recurrence of an SSO, at least for the identified Cause. Specific Mitigations are very dependent on the conditions observed from the CCTV video and report. This indicates the condition of infrastructure where SSOs are occurring. Table 4 provides a summary of the various Mitigations. The Mitigations are tracked through completion or implementation. (Note: Percentages may not add up to 100%, as they are rounded to the nearest percent.)
Table 4 Summary Mitigations from SSO Study
10-42, 10-48 Mitigations No Follow Up Needed Pretreatment Notified/Short Interval Rehab/Replace Short Interval Short Interval/Rehab/Replace Short Interval/Special Instructions Special Instructions
Grand Total
Total 1
1 4 5 1 4 2 18
% of Total 6%
6% 22% 28% 6% 22% 11% 100%
Page 8 of 26
SSO Tabulation & Analysis Figure 1 shows the cumulative 10-42s by month for CY2012-21.
10-42 SSOs Cumulative in the Collection System
90
80
70
60
50
40
30
20
10
0 Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec
CY 12 11
25
37
47
55
59
62
64
67
72
76
82
CY 13 13
22
30
33
37
41
44
49
54
58
66
72
CY 14 6
7
12
18
22
25
31
33
37
40
42
44
CY 15 9
17
23
26
31
34
35
39
39
43
50
54
CY 16 3
8
10
14
20
21
21
22
22
26
28
35
CY 17 5
11
13
16
19
20
22
23
24
27
36
40
CY 18 4
7
11
11
12
14
16
17
18
23
26
27
CY 19 6
6
10
12
16
18
19
22
22
23
26
26
CY 20 2
5
7
10
11
13
13
13
13
15
16
17
CY 21 2
2
4
8
8
8
9
9
9
9
10
12
CY 12 CY 17
CY 13 CY 18
CY 14 CY 19
CY 15 CY 20
CY 16 CY 21
Figure 1 Reportable SSOs
Page 9 of 26
Appendix 1 contains a list of every 10-42 and 10-48 event in CY2021. The table columns are grouped as follows:
1. The type, i.e., 10-42 or -48, is identified on the left. In one case a single event was both a 10-42 and a 10-48, as indicated.
2. Next to the right are the data included in the monthly SSO DMRs. It is noted that a "Reported Cause" is listed. This is typically based on the observations of the Operator that reported the SSO.
3. Next to the right is data determined by the Study Team: a. Cause b. Mitigation c. If Pretreatment follow-up is necessary
4. To the far right are follow-ups by NPDES Pretreatment a. FSEs visited b. Notice of Violation issued
The SSO Rate is defined as 100 times the number of SSOs in a year divided by the miles of sewer in the system. The Water Authority system has a total of approximately 2,414 miles of line (p. 8 of the Self-Assessment). The SSO rate is therefore 3.4, 3.0, 1.8, 2.2, 1.4, 1.7, 1.1, 1.1, 0.7 and 0.5 for CY2012-21 respectively. Figure 2 shows the total sewer troubles, i.e. 10-40s, -42s, and -48s by year for CY2012-21. This graph does not include 10-48s due to "burps" which are not due to a blockage or other failure resulting in the overflow of sewage. Instead, air displaced during the Vactor jetting cleaning can under certain circumstances force out the water in the home fixture P-traps, e.g. toilets and sinks. These sometimes result in claims and are therefore included in the Property Damage totals for completeness and consistency. There were only two burps during CY 2021. These burps are identified in Appendix 1.
Page 10 of 26
Sewer Trouble in Collection System Comparison CY12-C21
250
200
192
183
150 122 106
100
72
50 45
16
14
0 CY 12 CY 13
157
139 136 120 103
71
67
68
54
44 40 35
24
15
17
14
114
88 81
96 88
72
70
50
27
26
11 7 7 6 17 12
CY 14 CY 15 CY 16 CY 17 CY 18 CY 19 CY 20 CY 21
10-40 Backup 10-42 Overflow 10-48 Property Damage -Total Sewer Trouble
Figure 2 Sewer Trouble Comparison
Volume Spilled and Recovered
Via the OERP, the Water Authority has implemented a policy of capturing spills and documenting actions. Appendix 1 provides the Ultimate Discharge Location for each reported SSO. Appendix 2 provides estimated spill volumes and volumes recovered for 12 reported SSOs for CY2021. Of the spill volume estimated not to be recovered, none were identified as directly reaching the Rio Grande. No spills reached a facility operated by the MRGCD. It was estimated that approximately 83% of the estimated spill volume was recovered in CY2021 as shown in Appendix 2.
Page 11 of 26
Actions Implemented and On-Going Programs
General Below are gaps that were identified in the CY2020 CMOM Report and were closed in CY2021, or are on-going programs, or both. In addition to the commitments made in the CMOM Report, in CY2021, the following additional actions were taken to expand the Water Authority's ability to operate and maintain the system.
1. Interceptor manhole inspection was performed on 260 additional manholes for a total of 360 manholes inspected from CY2020 and CY2021. The data is being used for an Interceptor Manhole Asset Management Plan to determine which manholes should be prioritized for rehabilitation or replacement.
2. The Water Authority updated the public website (https://www.abcwua.org/sewercollection-section/ ) to provide more information about the Collection Section and make the website more user friendly. The "Keeping Elephants Out of Sewer Game," created by Stephanie Ramsey, Ph. D., was added to the website as a tool to teach the public how to prevent SSOs.
3. The Water Authority's Public Affairs section continued to support SSO prevention efforts and the FOG Policy in CY2021. Appendix 3 identifies media specifics for water bill inserts, social media, and advertising in television, radio, newspaper, outdoor boards, and digital.
4. On April 7, 2021, Collection Section staff met virtually with the North and South Divisions of LA Sanitation and Environment - Clean Water Conveyance. During the meeting, operating and management staff discussed cleaning methods and working in traffic conditions.
Page 12 of 26
FOG Policy Implementation The FOG Policy is an on-going program and FOG Enforcement efforts are a part of this program. Both the FOG Policy and the FOG Enforcement efforts are described above. On-going efforts are described in the FOG Enforcement section and not reiterated here. The Water Authority has long had an FSE flier in English. An FSE flier in Spanish was developed and implemented in CY2019 and a goal was set to develop an FSE flier in Chinese. However, it was determined that a Vietnamese flier was more prudent and this was developed in CY2020. The Water Authority has a three-year plan to distribute these fliers to all FSEs and residential units during SSO investigations to continually improve education to the rate payers on the negative impacts of FOG. In CY2022, improve FOG inspections by using advance inspection tools. Overflow Emergency Response Plan (OERP) This is an on-going program to update the OERP as required. In CY2020 and CY2021, no modifications were made were made to the OERP. The Collection Section is the "owner" of the OERP. The Collection Section creates the components of the OERP, routes for internal review (specifically including the Compliance Division), and the completed portions are approved for posting to SharePoint by the Collection Section Manager. Appendix 4 provides the OERP which was in effect at the end of CY2019. The most current version of the OERP is posted to http://www.abcwua.org/Sewer_System.aspx The Albuquerque Metropolitan Arroyo Flood Control Authority (AMAFCA) and the Water Authority continued coordination in 2021. On April 4, 2021, both organizations participated in a virtual brainstorming meeting. Discussion included improvements in capturing and removing spills prior to reaching the Rio Grande.
Page 13 of 26
Closed Circuit Television (CCTV) This is an on-going program. The following recommendation is made in the FY2013 CMOM Report: "CCTV inspections of the collection system as follows: 1) Small diameter main lines less than 15": In four of five years, televise approximately 5% per year of the small diameter system. Televise high risk lines based on current Asset Management Plan and subsequent inhouse analysis. 2) Large diameter lines 15" and larger: Every fifth year, televise as much as possible acknowledging access limitations of the unlined concrete lines 15" and larger. Anticipated schedule: 3) FY2014-17: 5% of the small diameter each year. 2) FY18: Large diameter unlined concrete pipe." CMOM Report figures for cleaning and CCTV will continue showing fiscal year (FY) goals in accordance with funding and contracting cycles and actual metrics will reflect work through the end of the calendar year (CY). Figure 3 provides the CCTV goal for a ten-year basis and the actual CCTV inspection through CY2021. The CY2021 portion of this recommendation is complete. The CCTV program will continue. Anticipated schedule:
1. FY21: 5% of the small diameter. 2. FY22: 5% of the small diameter. 3. FY23: Large diameter unlined concrete pipe. 4. FY24: 5% of the small diameter. 5. FY25: 5% of the small diameter. 6. FY26: 5% of the small diameter.
Figure 3 Small Diameter Sewer CCTVed vs. Ten-Year Goal
Page 14 of 26
Cleaning Program Goal This is an on-going program. The following recommendation is made in the FY2013 CMOM Report: "The Water Authority will establish and monitor a goal of cleaning all gravity small diameter lines every ten years. (This will be accomplished through the existing Sub-Basin program.) The Water Authority will continue the program of high-frequency maintenance of known problem locations within the system. (This will be accomplished through the existing Short Interval program.) The frequency of Short Interval cleaning will vary in accordance with system performance and risk factors, maintenance history, and the latest maintenance findings."
CMOM Report figures for cleaning and CCTV will continue showing fiscal year (FY) goals in accordance with funding and contracting cycles and actual metrics will reflect work through the end of the calendar year (CY). As shown Figure 4, the Water Authority is ahead of its goal to clean then entire system once in ten years through the Sub-Basin program.
The Water Authority has performed detailed analyses of SSO rates in the Water Authority collection system. These analyses show that:
1. The Short Interval lines consistently experience a higher SSO rate than the Sub-Basin lines. This indicates that even more cleaning of Short Interval lines, with a commensurate decrease in Sub-Basin cleaning, will result in a net reduction of total SSOs in the system. This is because the additional cleaning would be applied to lines more likely to spill, and to be taken from lines less likely to spill.
2. The upstream portion of the Sub-Basin lines are less likely to spill than the downstream portion.
These findings provide the opportunity to clean the sewers more effectively and efficiently with the goal of SSO reduction, therefore, in CY2022:
1. The Water Authority will establish and monitor a temporary goal of cleaning all gravity small diameter lines every fifteen years. (This will be accomplished through the existing Sub-Basin program.) The Water Authority will continue the program of high-frequency maintenance of known problem locations within the system. (This will be accomplished through the existing Short Interval program.) The frequency of Short Interval cleaning will vary in accordance with system performance and risk factors, maintenance history, and the latest maintenance findings. This will maintain the Sub-Basin program as currently configured while targeting the Short Interval lines which are more likely to spill.
2. The Water Authority will continue studies with the intent is to validate prior study indicating a significant SSO Rate variation for top versus bottom, and therefore the opportunity to optimize sub-basin cleaning. A possible outcome will be modification of the Sub-Basin program to remove lines shown to be significantly less likely to spill.
Page 15 of 26
Figure 4 Small Diameter Sewer Cleaned vs. Ten-Year Goal Force Main Inspection Program This is an on-going program in which the alignment is annually inspected for all force mains and valves found in field are compared to those in the GIS mapping and this information is stored in Maximo. Lift Station 20 pumps westside flow to the Southside Water Reclamation Plant (SWRP) via twin 30" ductile iron force mains. In CY2021, the Water Authority performed a test using the smart ball and installed replacement ARVs on both force mains. Odor Complaints Odor complaints are tabulated and reported monthly. The Water Authority odor control program is described in the CMOM Self-Assessment Report in the Hydrogen Sulfide Monitoring and Control (HSMC) section in the current CMOM Program Self-Assessment.
Page 16 of 26
Identified Gaps in the Water Authority Processes with Recommendation to Close
In the process of continuous improvement, the Water Authority is committed to identifying and closing gaps. As discussed above, most of these recommendations are now considered On-Going programs. Prohibited Discharges, i.e., SSOs The Water Authority acknowledges that prohibited discharges have occurred and that all discharges from the sanitary sewer system are prohibited. Recommendation: The Water Authority will annually examine sewer system performance, set specific steps for decreasing SSOs and mitigating their impacts, and has a program of continuous improvement.
Page 17 of 26
Appendices
Page 18 of 26
Appendix 1
Sanitary Sewer Overflow Analysis Table
Page 19 of 26
10-42 10-48 10-42 &10-48
Type
X X X
X X X X X
X X X
X X X X X X X
DMR
SSO Team Study Enforcement
Maximo WO #
Repeat Diameter Repeat within
1 year
Date of SSO
Time of Duration SSO (HH:MM)
Location
Estimated Volume (gallons)
Reported Cause of Overflow
Observed Environment
Impacts
Action Taken
Ultimate Volume Discharge Recovered Location (gallons)
1411937
8
1426602
8
1428140 NA
1483611
8
1479870
8
1491553
8
1507479
8
1516878
12
1523300
8
1525858
8
1633951
12
1635825
8
1760532
8
1760997
8
1783146
8
1799077
8
1801711
8
1814119
8
Y
N 1/5/2021 8:00 AM :45
7809 BELLAMAH AVE NE
NA
BP
NA
CC/IN
NA
N
N 1/22/2021 8:55 AM :35
1228 DEL MASTRO DR SW
700
GR/RGS
NEAH
CC/HTH/WD
PST
N
N 1/23/2021 5:27 PM 2:18
COORS BLVD SW & PAJARITO RD SW
100 CONTROLLER NEAH CNTRLR/SSS/CV/ET /PO/RPLC/HTH PST
N
N 3/8/2021 11:41 AM 0:49
1843 CAGUA PL NE
NA
RGS
NA
CC
NA
N
N 3/5/2021 9:57 AM 0:18
3528 CAMPBELL FARM LN NW
55
GR/RGS
NEAH
CC/HTH/WD/RP
O
N
N 3/17/2021 12:25 PM 0:55
4001 PRINCE ST SE
275
RGS
NEAH CC/HTH/CWW/WD PST
N
N 4/3/2021 7:07 PM 3:53
13004 GLENWOOD HILLS CT NE
50
RGR
NEAH
CC/HTH/RS/WD
AD
N
N 4/10/2021 8:25 AM 1:52
6200 INDIAN SCHOOL RD NE
5600
DB/V
NEAH CC/HTH/PO/CWW/R S/WD AC
Y
N 4/17/2021 2:59 PM 0:44
DON LUIS RD SW
220
GR/RGS
NEAH CC/HTH/CWW/RP/ WD STD
N
N 4/20/2021 6:55 PM 0:20
4401 4TH ST NW
100
GR
NEAH
CC/WD
PST
N
N 7/31/2021 1:09 PM 2:41
7228 VALLE JARDIN LA NW
800
GR/RGS
NEAH
CC/HTH
SD
N
N 8/2/2021 1:25 PM :40
6108 BANCROFT CT NE
NA
RGS/RT
NA
CC/HTH
NA
N
N 11/16/2021 7:00 PM 0:30
2900 EL CORTO DR SW
NA
BP
NA
CC
NA
N
N 11/18/2021 8:21 AM 1:00 MARLA DR NE & MONTGOMERY BLVD NE 1500
RGS
NEAH
CC/HTH/RS/WD
SD
Y
Y 12/6/2021 12:23 AM 0:17
1600 GONZALES RD SW
NA
GR
NA
CC
NA
N
N 12/18/2021 11:00 AM 0:50
7900 SAN PEDRO DR NE
3100
GR/RGS
NEAH CC/HTH/PO/RP/WD/ ET AC
N
N 12/20/2021 8:00 AM 0:30
620 13TH ST NW
NA
GR
NA
CC
NA
N
N 12/25/2021 1:55 PM 0:20
13125 ALICE AVE NE
100
GR
NEAH
CC/HTH/WD
PST
NA
BP
SP
600
MH RH
0
EQ RPLC
NA
RT
SI
55
GR/RGS RH/SI
275
EQ RH
0
RGR SI
5600
V
NF
110
LF
RH
0
GR PT/SI x 3 2
800 GR/RGS SI
NA
RT SI/SP
NA
BP
SP
500
RT SI/SP
NA
SL
SI
2500
GR SI/SP x
NA
SL
SI
35
RT SI/SP
Cause Mitigation Pretreatment Follow Up Requested FSEs Visited Notice of Violation
Page 20 of 26
Appendix 2
Sanitary Sewer Overflow Volume Captured Analysis Table
Page 21 of 26
Maximo WO #
1426602 1428140 1479870 1491553 1507479 1516878 1523300 1525858 1633951 1760997 1799077 1814119 Grand Total
CY2021 10-42 SPILL VOLUME AND VOLUME RECOVERED
Estimated Volume
Date of SSO
Location
Volume Recovered
(gallons) (gallons)
1/22/2021
1228 DEL MASTRO DR SW
700
600
1/23/2021
COORS BLVD SW & PAJARITO RD SW
100
0
3/5/2021
3528 CAMPBELL FARM LN NW
55
55
3/17/2021
4001 PRINCE ST SE
275
275
4/3/2021
13004 GLENWOOD HILLS CT NE
50
0
4/10/2021
6200 INDIAN SCHOOL RD NE
5600
5600
4/17/2021
DON LUIS RD SW
220
110
4/20/2021
4401 4TH ST NW
100
0
7/31/2021
7228 VALLE JARDIN LA NW
800
800
11/18/2021 MARLA DR NE & MONTGOMERY BLVD NE
1500
500
12/18/2021
7900 SAN PEDRO DR NE
3100
2500
12/25/2021
13125 ALICE AVE NE
100
35
12,600
10,475
Volume Not
Recovered 100 100 - - 50 - 110 100 -
1,000 600 65 460
% Recovered
86% 0% 100% 100% 0% 100% 50% 0% 100% 33% 81% 35% 83%
Appendix 3
FOG Advertising Campaign
Our CY2021 FOG advertising campaign/public outreach was supported by the following activities:
Bill Inserts (210,000 printed and distributed every month) December 2021 November 2021
Outdoor Advertising 4 Outdoor boards running for one week from Nov. 22-28, 2021 and Dec. 20-27, 2021 reaching an estimated 1,505,201 residents (with duplication)
Newspaper Advertising 2 banners ads running in the Albuquerque Journal on 11/24/21 and 12/22/21 reaching an estimated 193,650 people. 2 one-quarter page ads running in The Paper on 11/24/21 and 12/22/25 reaching an estimated 20,000 people.
Television advertising 2 week schedules in November and December on KOB TV, KRQE TV and KOAT TV and selected Comcast stations reading an estimated 998,542 people.
Digital advertising Digital place on AdWallet in November and December targeting women 27-65 in Bernalillo County zip codes. Estimated number of people reached: 5,000
Radio advertising Two week scheduled in November (11/15/21-11/28/21) and December (12/20/2112/26/21) on the top 5 local stations reaching women 25-64. Estimated number of people reached: 212,872
Total number of estimated people reached (with duplications): 3,541,965
Social Media Posts - Facebook/Instagram/Nextdoor
DATE PUBLISHED 22-Dec-21 22-Dec-21 23-Nov-21 23-Nov-21 22-Nov-21 22-Oct-21 28-Aug-21 15-May-21 29-Jan-21
Data - Social Media Posts
PEOPLE REACHED
37
ENGAGEMENTS ---
LIKES AND REACTIONS
2 LIKES
COMMENTS SHARES
0
0
214
11
8 REACTIONS
0
2
66
---
4 LIKES
0
0
1.3 K
30
8 REACTIONS
0
1
248
8
4 REACTIONS
0
2
239
6
3 REACTIONS
0
2
187
17
9 REACTIONS
1
1
412
23
17 REACTIONS
0
4
134
3
3 REACTIONS
0
0
Appendix 4
Overflow Emergency Response Plan (OERP)
Overflow Emergency Response Plan
Albuquerque Bernalillo County Water Utility Authority
Customer calls dispatch with issue
Dispatch collects data and creates
a Service Request; Task
elevated to supervisor
Note: All Emergency responses are initiated by a call to Dispatch at 842WATR (842-9287). Please call there
first. If you do not, the emergency responders have to call and delay the
response
Collection Response
Follow up study and mitigation.
Pg. 6
Notification process. Pg. 7
Alert Media. Pg. 10
12-1-2019
Applies only to Collection System sewer problems.
Supervisor creates a work order and sends crew to
location. Status of work order is updated to DISPATCHED
Spill to pervious areas.
Pg. 3
Spill entered / entering storm drain collection system. Pg. 4
Private vs. public SSO.
Pg. 5
Spill has entered storm pump station.
Pg. 9
Spill entering Waterway.
Pg. 11
Unblock and Clean up. Pg. 2
Tech confirms asset and fills out required information in the
work order
Supervisor reviews work order for quality assurance.
Status of work order is updated to COMPLETE AND
READY FOR REVIEW
Planner / Scheduler does quality control and updates
status of work order to COMPLETE
Page 1
Overflow Emergency Response Plan
Albuquerque Bernalillo County Water Utility Authority
12-1-2019
Unblock and Clean Up. Pg. 1
Crew arrives on site
Clean Sewer. Pg. 5
Is SSO clearly public?
No
Note the time Yes of dispatch and
arrival on scene
Private vs. Public SSOs.
Pg. 5
Investigate the cause and stop the
sanitary sewer overflow.
Protect public from area.
Note the start and stop time that the overflow occurred
Apply HTH per SOP
If evidence of "Extreme" FOG.
Is additional help necessary to aid the clean up / remediation
efforts?
The Vactor truck(s) Yes should be
dispatched immediately.
No
Pretreatment Involvement.
Pg. 8
Remove spill from surface. Remove any solids. Wash down spill area and remove wash water.
Determine whether overflow has entered pervious area, storm drain, ditch, canal, or storm pump station.
Spill has entered a waterway.
Pg. 11
Spill to pervious area.
Pg. 3
Spill entered / entering storm drain collection system. Pg. 4
Spill has entered a COA storm pump station. Pg. 9
Page 2
Overflow Emergency Response Plan
Albuquerque Bernalillo County Water Utility Authority
Spill to pervious area. Pg. 2
Immediately begin collecting spill with
Vactor truck.
When SSO stopped, apply washwater & HTH to spill area &
allow to flow to pervious area and remove washwater.
Supervisor or Superintendent to
determine / recommend remediation. Consult with Chief Engineer if required.
Yes
Supervisor or
Superintendent to
determine if public
No
access to pervious
area is a concern.
Implement Allow to dry.
Remediation Complete. Pg. 1
12-1-2019
Page 3
Overflow Emergency Response Plan
Albuquerque Bernalillo County Water Utility Authority
Spill entered / entering storm drain collection system. Pg. 2
If possible, position 2nd Vactor to
remove spill prior to reaching inlet.
Determine how far downstream the spill has reached.
12-1-2019
SSO Reaches AMAFCA Facility
Name Jerry Lovato*
Bernalillo County Facility Patrick E. Chavez#
Contact Position Executive Engineer
Storm Drainage Maintenance Manager
Office 884-2215
848-1505
NMDOT Facility COA Facility
Thomas Kratochvil Kathy Verhage **
District 3: Assistant District Engineer-Maintenance
Senior Engineer
N/A 768-2778
Cell 362-0020 934-2704
228-8169 803-8058
Add wash water & remove at downstream manhole. Remove immediately if rain is imminent. If not, remove
next normal work day.
Wash water to street and inlet.
SSO Reaches COA storm drain.
Assist in clean up as requested.
Remediation Complete.
Pg. 1
Note: Process shown is for typical spills. Spills that are not appropriate for Vactor removal may require a joint response with the impacted MS4 Permittee in which the spill is captured, treated, and determined appropriate for release.
*If Jerry Lovato is not immediately available, call:
Nolan Bennett: Field Engineer (505) 301-6941 Sal Hernandez: Superintendent (505) 366-8209
**If Kathy Verhage is not immediately available, call:
David Harrison: Engr. Div. Manager (505) 238-4158 Carl Rinkenberger: O&M Manager (505) 250-4334 Daniel Tapia: O&M Supt (505) 228-6874
#If Patrick E. Chavez is not immediately available, call: Kali Bronson: Stormwater Program Compliance Manager (505) 401-1779
Page 4
Overflow Emergency Response Plan
Albuquerque Bernalillo County Water Utility Authority
Private vs. Public SSOs.
Pg. 2
12-1-2019
Ask Supervisor.
City of Albuquerque Code Enforcement (505) 924-3450
Bernalillo County Natural Resource Services Review & Permitting Section
(505) 314-0375
Village of Los Ranchos (505) 344-6582
Code Enforcement office
NMED Liquid Waste Program (505) 222-9500
(505) 827-1840
For non-Authority spills in the County, in addition to calling Natural Resources Services, contact Patrick E. Chavez at 934-2704. For any nonAuthority that impact an AMAFCA or NMDOT
facility, alert the appropriate contact listed on page 4.
For non-Authority spills in the City limits, in addition to calling the appropriate portion of COA
Code Enforcement, also alert: Kathy Verhage - (505) 803-8058
Clearly Public? No Elevate to
Clearly Private? No Superintendent.
Yes Resolve if Yes
Public?
Yes
Inform Public
No
Clean Sewer. Pg. 2
Do not clean sewer
Depending on jurisdiction, follow up with City of
Albuquerque, Bernalillo County, Village of Las Ranchos or NMED
(See table for contacts)
Remediation Complete.
Pg. 1
Note: The identified code enforcement contacts will also be utilized to report private service lines issues resulting in sewage spills to private or public property.
Public and private lines may be differentiated on the Water Authority GIS Mapping.
Private lines that may be confused with Water Authority mains should be identified to the Collection Section Research Analyst for inclusion in the "Waste Water NonAuthority" layer.
Page 5
Overflow Emergency Response Plan
Albuquerque Bernalillo County Water Utility Authority
Follow up study and mitigation.
Pg. 1
12-1-2019
*If the defect is due to corroded concrete, rehab of the manhole to manhole pipe segment is typically forwarded directly to
Centralized Engineering for assignment to an On-Call contractor or inclusion in planned rehab project. If the defect is in a VCP line, Assistant Superintendent/ Gravity Superintendent/ Construction Supervisor will make the determination.
Research Analyst/GIS Intern creates a follow-up cleaning
and CCTV work orders for gravity 10-40s, -42s, and 48s.
Sewer line is televised.
Research Analyst compiles maps and data associated with all unstudied 10-42s and 48s for SSO Study
Team Meeting.
SSO Team examine/
request more data/
No
resolve.
Consensus cause. Consensus mitigation.
Is a defect identified as Grade
7 or 8?
Will it be assigned
Yes
in-house or to on-
call contractor?*
On-Call
Forward to Centralized Engineering and copy Collection Section Manager, Gravity
Superintendent, and Research Analyst.
No
Research Analyst studies SSOs.
Obvious cause?
In-House Create Maximo
Work Order. Yes
Research Analyst compiles SSO cause
and mitigation
Consent List SSO Team accepts/ requests further
study
Accepted Cause. Accepted Mitigation.
Compile data in SSO Analysis Table for inclusion in CMOM Report.
Review with Collection Section Manager for suggestions and approval.
Non-FOG
Collection Section Manager approves and routes for implementation.*
Mitigation
FOG
End of Pretreatment involvement.
Pg. 8
Submit to Pretreatment for
enforcement. Pg. 8
SSO Tracking Table
Page 6
Overflow Emergency Response Plan
Albuquerque Bernalillo County Water Utility Authority
Notification Process. Pg. 1
Document but do not report.
No Reporting Yes
No
For system breaks resulting in release on KAFB: Call
Kirtland AFB Command Post at (505) 846-3777 within 12
hours.
For spills on the UNM Main and North Campus contact the Work Control Center (M-F 7:00 a.m. to 4:30 p.m.) at (505) 277-1600 and all other
times contact the Campus Police at (505) 277-2241.
Spill from WUA System?
Spill contained in
WUA Facility (e.g. dry
No
well)?
N o Yes
Spill results from contractor's work or construction activity
(Section 911).
Yes
Contractor verbally reports to collection
section Superintendent or standby Supervisor.
Contractor provides 24 hour written report.
EPA DMR, 15th of the month
Compliance Division
DMR Collection Section SSOs
12-1-2019
Yes
Spill contained in private facility (e.g.
basement SSO)?
No
GWQB Reporting Ponded sewage on a pervious area may require additional reporting to the Ground Water Quality Bureau (GWQB). Circumstances presumed to require this reporting will be: 1. A sewage spill that: a. Is ponded for more than 24 hours and, b. At a depth of more than 12 inches over an area of more than 0.1 acre. The normal 24-hour call to NMED Surface Water is presumed to meet the requirement for a 24-hour notification to the GWQB. The Collection Section Manager shall be notified and shall be responsible for preparing the following additional reporting: 1. One week written report. Presumed the same as the five day report provided to NMED Surface Water. 2. 15-day Corrective Action Report.
O & M Supervisor Reports
Within 24 hrs. of time of
dispatch notified or contractor verbally reports
Assistant Superintendent prepares written report. Field Division Manager
signs.
Within 5 days
Oral report NM Environment Dept. Email report EPA POI
Written Report EPA NM Environment
Department Pueblo of Isleta
Collection Section Manager to COA &
AMAFCA
Note: This page shows Oral and Written Reports for "typical" SSOs. See page 11 for reports of "Category One" SSOs.
Page 7
Overflow Emergency Response Plan
Albuquerque Bernalillo County Water Utility Authority
Pretreatment Involvement.
Pg. 2
Submit to Pretreatment for
enforcement. Pg. 6
12-1-2019
Supervisor calls Pretreatment Office Assistant (289-3419)
o Address o Date o Time o Supervisor Name o Estimated Volume
Is P2 spec. available?
Yes P2 spec. investigates
No
Pretreatment Engineer
Investigates
Proceed to SSO Location
Observe site, fill out form, take pictures, and collect sample if
possible
Use mapping resources to establish upstream basin area
Develop list of FSEs in area
Note any problem FSEs.
LINKO Generated Notice of Violation
(NOV)
Start Enforcement Yes Process
Is a FSE responsible?
No
Update SSO Tracking Table.
Pg. 6
Visit FSEs and check GRSs and manifests
Page 8
Overflow Emergency Response Plan
Albuquerque Bernalillo County Water Utility Authority
Spill has entered a COA storm pump station. Pg. 2
Shut down pumps
Remove sewage with Vactor or pump
to SAS
Wash down wet well and remove wash water
Remediation Complete.
Pg. 1
Note: Process shown is for typical spills. Some spills may require a joint response with the City of Albuquerque in which the spill is captured, treated, and determined appropriate for release.
12-1-2019 Page 9
Overflow Emergency Response Plan
Albuquerque Bernalillo County Water Utility Authority
Alert Media. Pg. 1
For large or significant spills.
Superintendent, Chief Engineer, or Division Manager to contact Public Affairs Manager (PAM), Dave Morris, or Chief Operating Officer
(COO), John Stomp. Provide required information.
Media alerted by PAM, COO, or designee
12-1-2019
Page 10
Overflow Emergency Response Plan
Albuquerque Bernalillo County Water Utility Authority
Spill has entered a waterway.
Pg. 2
Reaches Rio No Grande?
If possible, stop the
No
flow from entering
Reaches MRGCD
the waterway and
Facility?
collect wastewater.
Yes
Contact (In sequence until contacted)
Jason Casuga Engineering
(505) 259-1005
Joe Brem
ABQ Division Manager
(505) 249-5780
Mike Hamman CEO / Chief Engineer
(505) 206-6378
Pg. 12 Sample MRGCD facility
for E. coli upstream and downstream of SSO.
12-1-2019
No Remove debris.
Yes Pg. 1
Is spill fully contained?
Yes Assist in
cleanup as requested.
No
Category One SSO
Immediately following the overflow event, contact the following numbers until a live person is reached. In the event there is no answer, leave a message on each number.
Position
POI Category One Protocol Contacts
Name
Cell Number
Office Number
Emergency Dispatch
N/A
N/A
(505) 869-3030
Environment Division Manager
Ruben Lucero (505) 917-8346 (505) 869-9819
Transportation Division Manager
James Weldon
(505) 933-1225 or
(505) 417-0124
(505) 869-9818
Water Quality Specialist Cody Walker (505) 220-4595 (505) 869-9623
Page 11
Overflow Emergency Response Plan
Albuquerque Bernalillo County Water Utility Authority
Pg. 11 Sample MRGCD facility for E. coli upstream and downstream of SSO.
12-1-2019
Contact NPDES Program Manager
(505) 274-0271 cell
Pretreatment Sampling Staff Meet On-Site
Agree on Sampling Location in Coordination with Collection Section
and/or MRGCD Staff
Obtain Sample Upstream and Downstream of SSO
Transport to SWRP Water Quality Lab
Test per E. coli Method SM9223-B-2004
or Other Approved EPA Method
Provide Results to Collection Section
Manager
Page 12
Appendix 5
Goal Summary - CY2021 Report
Page 26 of 26
Goal Summary - CY2021 CMOM Report
Goal
Timing
Submit FOGS and Enforcement Policies to EPA for
approval once the legal review is complete
TBD
Page # for Discussion
4
CCTV all gravity pipes suffering a blockage. For all SSOs,
determine a cause and mitigation and report in the next
Annually
6
CMOM report
Public advertising
On-Going
12
Distribute FSE fliers in English, Vietnamese and Spanish, and CY2023 12 improve FOG inspections by using advance inspection tools
Update OERP CCTV a portion of system Clean a portion of the system
As required
13
Report Ten Year goal. 14 Report Ten Year goal. 15
Establish and monitor a temporary goal of cleaning all gravity CY2022 15 small diameter lines every fifteen years
Update frequency of Short Interval cleaning in accordance
with system performance and risk factors, maintenance
CY2022
15
history, and the latest maintenance findings
Force main inspection program SSOs: Take steps to decrease and mitigate
Annually
16
On-Going
17
ABCWUA/Southside Water Reclamation Plant (SWRP) NPDES Permit No. NM0022250 Albuquerque, New Mexico Inspection Date 09/21/2022
Appendix 3
Review of the Integrated Compliance Information System (ICIS)
Database For
the period from
January 1, 2020, to September 20, 2022
9/20/22, 12:30 PM
FE&C
NPDES
AIR
ICIS: Search Violation Results
Admin
Reports Help
DESPARZA
Logout
Search Permits Related NPDES Violations
ADD SINGLE EVENT VIOLATION
List of Violations Related to the Permit
Violation Type Violation Information
Violation Violation Code Date
RNC Detection Code-Date
Record Numbers 1 to 79
RNC Resolution Code-Date
Action
Single Event Violation
D0017 Permit Violations - Violation Specified in Comment D0017
01/12/2020
Delete
Single Event Violation
D0017 Permit Violations - Violation Specified in Comment D0017
01/17/2020
Delete
Single Event Violation
D0017 Permit Violations - Violation Specified in Comment D0017
02/12/2020
Delete
Single Event Violation
D0017 Permit Violations - Violation Specified in Comment D0017
02/18/2020
Delete
Single Event Violation
R013S Dry-weather SSO, no discharge to waters of the U.S., that may endanger health or the environment
R013S 02/18/2020
Delete
Single Event Violation
R013S Dry-weather SSO, no discharge to waters of the U.S., that may endanger health or the environment
R013S 02/27/2020
Delete
Single Event Violation
R013S Dry-weather SSO, no discharge to waters of the U.S., that may endanger health or the environment
R013S 02/29/2020
Delete
Single Event Violation
R013S Dry-weather SSO, no discharge to waters of the U.S., that may endanger health or the environment
R013S 03/12/2020
Delete
Single Event Violation
R013S Dry-weather SSO, no discharge to waters of the U.S., that may endanger health or the environment
R013S 03/24/2020
Delete
Single Event Violation
R013S Dry-weather SSO, no discharge to waters of the U.S., that may endanger health or the environment
R013S 04/01/2020
Delete
Single Event Violation
R013S Dry-weather SSO, no discharge to waters of the U.S., that may endanger health or the environment
R013S 04/18/2020
Delete
Single Event Violation
R013S Dry-weather SSO, no discharge to waters of the U.S., that may endanger health or the environment
R013S 04/30/2020
Delete
Single Event Violation
R013S Dry-weather SSO, no discharge to waters of the U.S., that may endanger health or the environment
R013S 05/01/2020
Delete
Single Event Violation
R013S Dry-weather SSO, no discharge to waters of the U.S., that may endanger health or the environment
R013S 06/16/2020
Delete
https://icis.epa.gov/icis/permit/SearchViolation.do?fromSearchCriteriaPage=true&compositeKey=3602020885@NPD&navActivityId=3602020885&nav... 1/5
9/20/22, 12:30 PM
ICIS: Search Violation Results
Violation Type Violation Information
Violation Violation Code Date
RNC Detection Code-Date
Single Event Violation
R013S Dry-weather SSO, no discharge to waters of the U.S., that may endanger health or the environment
R013S 06/27/2020
Single Event Violation
R013S Dry-weather SSO, no discharge to waters of the U.S., that may endanger health or the environment
R013S 07/24/2020
Single Event Violation
D0017 Permit Violations - Violation Specified in Comment D0017
10/06/2020
Single Event Violation
D0017 Permit Violations - Violation Specified in Comment D0017
10/12/2020
Single Event Violation
D0017 Permit Violations - Violation Specified in Comment D0017
11/26/2020
Single Event Violation
D0017 Permit Violations - Violation Specified in Comment D0017
12/15/2020
Single Event Violation
A0012 Effluent Violations - Numeric effluent violation
A0012 02/13/2021
Single Event Violation
D0017 Permit Violations - Violation Specified in Comment D0017
03/05/2021
Single Event Violation
D0017 Permit Violations - Violation Specified in Comment D0017
03/07/2021
Single Event Violation
D0017 Permit Violations - Violation Specified in Comment D0017
03/17/2021
Single Event Violation
A0012 Effluent Violations - Numeric effluent violation
A0012 03/24/2021
Single Event Violation
D0017 Permit Violations - Violation Specified in Comment D0017
04/03/2021
Single Event Violation
D0017 Permit Violations - Violation Specified in Comment D0017
04/10/2021
Single Event Violation
R013S Dry-weather SSO, no discharge to waters of the U.S., that may endanger health or the environment
R013S 07/30/2021
Single Event Violation
R013S Dry-weather SSO, no discharge to waters of the U.S., that may endanger health or the environment
R013S 07/31/2021
Single Event Violation
R013S Dry-weather SSO, no discharge to waters of the U.S., that may endanger health or the environment
R013S 11/18/2021
Single Event Violation
R013S Dry-weather SSO, no discharge to waters of the U.S., that may endanger health or the environment
R013S 12/18/2021
Single Event Violation
R013S Dry-weather SSO, no discharge to waters of the U.S., that may endanger health or the environment
R013S 12/29/2021
Single Event Violation
R013S Dry-weather SSO, no discharge to waters of the U.S., that may endanger health or the environment
R013S 01/13/2022
Single Event Violation
R013S Dry-weather SSO, no discharge to waters of the U.S., that may endanger health or the environment
R013S 01/17/2022
Single Event Violation
R013S Dry-weather SSO, no discharge to waters of the U.S., that may endanger health or the environment
R013S 01/18/2022
RNC Resolution Code-Date
Action Delete Delete Delete Delete Delete Delete Delete Delete Delete Delete Delete Delete Delete Delete Delete Delete Delete Delete Delete Delete Delete
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9/20/22, 12:30 PM
ICIS: Search Violation Results
Violation Type Violation Information
Violation Violation Code Date
RNC Detection Code-Date
RNC Resolution Code-Date
Action
Single Event Violation
R013S Dry-weather SSO, no discharge to waters of the U.S., that may endanger health or the environment
R013S 01/22/2022
Delete
Single Event Violation
R013S Dry-weather SSO, no discharge to waters of the U.S., that may endanger health or the environment
R013S 01/23/2022
Delete
Single Event Violation
R013S Dry-weather SSO, no discharge to waters of the U.S., that may endanger health or the environment
R013S 02/05/2022
Delete
Single Event Violation
R013S Dry-weather SSO, no discharge to waters of the U.S., that may endanger health or the environment
R013S 02/14/2022
Delete
Single Event Violation
R013S Dry-weather SSO, no discharge to waters of the U.S., that may endanger health or the environment
R013S 02/20/2022
Delete
Single Event Violation
R013S Dry-weather SSO, no discharge to waters of the U.S., that may endanger health or the environment
R013S 02/21/2022
Delete
Single Event Violation
R013S Dry-weather SSO, no discharge to waters of the U.S., that may endanger health or the environment
R013S 03/31/2022
Delete
Single Event Violation
R013S Dry-weather SSO, no discharge to waters of the U.S., that may endanger health or the environment
R013S 04/13/2022
Delete
Single Event Violation
R013S Dry-weather SSO, no discharge to waters of the U.S., that may endanger health or the environment
R013S 04/14/2022
Delete
Single Event Violation
R013S Dry-weather SSO, no discharge to waters of the U.S., that may endanger health or the environment
R013S 04/20/2022
Delete
Single Event Violation
R013S Dry-weather SSO, no discharge to waters of the U.S., that may endanger health or the environment
R013S 04/24/2022
Delete
Single Event Violation
R013S Dry-weather SSO, no discharge to waters of the U.S., that may endanger health or the environment
R013S 04/26/2022
Delete
Single Event Violation
R013S Dry-weather SSO, no discharge to waters of the U.S., that may endanger health or the environment
R013S 05/01/2022
Delete
Single Event Violation
R013S Dry-weather SSO, no discharge to waters of the U.S., that may endanger health or the environment
R013S 05/10/2022
Delete
Single Event Violation
R013S Dry-weather SSO, no discharge to waters of the U.S., that may endanger health or the environment
R013S 05/23/2022
Delete
Single Event Violation
R013S Dry-weather SSO, no discharge to waters of the U.S., that may endanger health or the environment
R013S 05/24/2022
Delete
Effluent Violation
001 A 71900 Mercury, total [as Hg] Effluent Gross Season E90
ID:0 C3
03/31/2020
Effluent Violation
001 A 51040 E. coli Effluent Gross Season ID:0 C3
E90
04/30/2020
Effluent Violation
001 A 71900 Mercury, total [as Hg] Effluent Gross Season E90
ID:0 Q2
04/30/2020
Effluent Violation
001 A 71900 Mercury, total [as Hg] Effluent Gross Season E90
ID:0 C2
04/30/2020 T-05/31/2020 2-08/31/2020
Effluent Violation
001 A 71900 Mercury, total [as Hg] Effluent Gross Season E90
ID:0 C3
04/30/2020
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9/20/22, 12:30 PM
ICIS: Search Violation Results
Violation Type Violation Information
Violation Violation Code Date
RNC Detection Code-Date
RNC Resolution Code-Date
Action
Effluent Violation
001 A 71900 Mercury, total [as Hg] Effluent Gross Season E90
ID:0 Q1
V05/31/2020
05/31/2020
2-08/31/2020
Effluent Violation
001 A 71900 Mercury, total [as Hg] Effluent Gross Season E90
ID:0 Q2
05/31/2020
Effluent Violation
001 A 71900 Mercury, total [as Hg] Effluent Gross Season E90
ID:0 C2
05/31/2020 T-05/31/2020 2-08/31/2020
Effluent Violation
001 A 71900 Mercury, total [as Hg] Effluent Gross Season E90
ID:0 C3
05/31/2020
Effluent Violation
001 A 71900 Mercury, total [as Hg] Effluent Gross Season E90
ID:0 C3
06/30/2020
Effluent Violation
001 A 50060 Chlorine, total residual Disinfection, Process E90
Complete Season ID:0 C3
08/31/2020
Effluent Violation
001 A 71900 Mercury, total [as Hg] Effluent Gross Season E90
ID:0 C3
08/31/2020
Effluent Violation
001 A 71900 Mercury, total [as Hg] Effluent Gross Season E90
ID:0 C3
09/30/2020
Effluent Violation
001 A 51040 E. coli Effluent Gross Season ID:0 C3
E90
10/31/2020
DMR NonReceipt Violation
001 Y 39516 Polychlorinated biphenyls [PCBs] Effluent D80
Gross Season ID:0 C3
K11/30/2020
01/15/2021
2-06/15/2021
Effluent Violation
001 A 71900 Mercury, total [as Hg] Effluent Gross Season E90
ID:0 C3
01/31/2021
Effluent Violation
001 A 51040 E. coli Effluent Gross Season ID:0 C3
E90
02/28/2021
Effluent Violation
001 A 51040 E. coli Effluent Gross Season ID:0 C3
E90
06/30/2021
Effluent Violation
001 A 71900 Mercury, total [as Hg] Effluent Gross Season E90
ID:0 C3
09/30/2021
Effluent Violation
001 A 51040 E. coli Effluent Gross Season ID:0 C3
E90
10/31/2021
Effluent Violation
001 A 71900 Mercury, total [as Hg] Effluent Gross Season E90
ID:0 C2
10/31/2021
Effluent Violation
001 A 71900 Mercury, total [as Hg] Effluent Gross Season E90
ID:0 C3
10/31/2021
Effluent Violation
001 A 51040 E. coli Effluent Gross Season ID:0 C3
E90
12/31/2021
Effluent Violation
001 A 51040 E. coli Effluent Gross Season ID:0 C3
E90
01/31/2022
Effluent Violation
001 A 51040 E. coli Effluent Gross Season ID:0 C3
E90
04/30/2022
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9/20/22, 12:30 PM
ICIS: Search Violation Results
Violation Type Violation Information
Violation Violation Code Date
RNC Detection Code-Date
Effluent Violation
001 A 00400 pH Effluent Gross Season ID:0 C1
E90
05/31/2022
Effluent Violation
001 A 51040 E. coli Effluent Gross Season ID:0 C3
E90
06/30/2022
Effluent Violation
001 A 71900 Mercury, total [as Hg] Effluent Gross Season E90
ID:0 C3
07/31/2022
RNC Resolution Code-Date
Action
Record Numbers 1 to 79
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ABCWUA/Southside Water Reclamation Plant (SWRP) NPDES Permit No. NM0022250 Albuquerque, New Mexico Inspection Date 09/21/2022
Appendix 4
Opening and Closing Conference Sign-in Sheets