Document mmnMwN7919jmZp8KDxEMd4qjB

Region 6 - Enforcement & Compliance Assurance Division INSPECTION REPORT Inspection Date(s): Media Program: Regulatory Program(s) April 14, 2025 Water CWA Company Name: Facility Name: Facility Physical Location: (city, state, zip code) Mailing address: (city, state, zip code) County/Parish: Facility Phone Number Facility Contact: City of Farmington Farmington Wastewater Treatment Plant 1395 South Lake Street Farmington, New Mexico 87401-2263 805 Municipal Drive Farmington, New Mexico 87401-2263 San Juan 505-599-1335 Benedikte Webb Operations Maintenance & Environmental Administrator bwebb@farmingtonnm.gov FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: SIC: 110017838722 NM0020583 N/A 221320 4952 Personnel participating in inspection: Benedikte Webb City of Farmington Devin Flaherty City of Farmington Operations Maintenance & Environmental Administrator Water/Wastewater Operations Manager David Esparza, P.E. USEPA/R6-ECDWM Environmental Engineer EPA Lead Inspector Signature/Date Supervisor Signature/Date DAVID ESPARZA Date: 2025.05.21 12:58:36 -06'00' Digitally signed by DAVID ESPARZA David Esparza Date ROBERTO BERNIER Roberto Bernier Digitally signed by ROBERTO BERNIER Date: 2025.06.02 16:51:51 -05'00' Date 6ENFORM-020-R8.2 (02/12/2020) 1 City of Farmington/Farmington Wastewater Treatment Plant NPDES permit No. NM0020583 Inspection Date April 14, 2025 Section I - INTRODUCTION PURPOSE OF THE INSPECTION United States Environmental Protection Agency (EPA) Region 6 inspector David Esparza, P.E., arrived at the City of Farmington (Farmington) Community Works Department at approximately 1:00 PM on April 14, 2025, for an unannounced inspection. I met with Ms. Benedikte Webb, City of Farmington Operations Maintenance & Environmental Administrator and Mr. Devin Flaherty, City of Farmington Water/Wastewater Operations Manager. I presented my credentials to Ms. Webb and Mr. Flaherty and informed them that this was an EPA inspection to determine the facility's compliance under the Clean Water Act (CWA) and the requirements 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 Farmington representatives, observations made by the EPA inspector, and records and reports maintained by the permittee, and the EPA. Additionally, we discussed the Capacity Management Operations and Maintenance (CMOM) checklist forwarded via electronic mail (email) earlier in our discussion (Appendix 1 Capacity Management Operations and Maintenance Self-Assessment). FACILITY DESCRIPTION The WWTP is a major discharger with a design flow of 6.67 million gallons per day (MGD), with an average daily flow of 4.3 MGD. The activated sludge treatment facility is located at 1395 South Lake Street, Farmington, San Juan County New Mexico (depicted in Aerial Image #1 below). The WWTP facility serves a population of approximately 50,000 persons. The WWTP was operated under contract agreement with CH2MHill (renewed in 2016). In late 2017, CH2MHill was acquired by Jacobs Engineering Group and associated employees and contracts were transitioned from CH2MHill to Jacobs. Currently the WWTP has seven (7) full-time equivalent (FTE) operators (3-certified and 4-operators-in-training (OIT)) and operates on overlapping 10-hour shifts, 24-hours per day. The WWTP also provides wastewater collection services to the communities of Kirtland and McGee Park, a county facility consisting of a racetrack and casino, Harper Valley Homeowners Association (decommissioned and treatment works removed in approximately August 2017) and hauled septic waste (septage) from San Juan County. The hauled septage equates to approximately 400-500 trucks per month at an average load of 1,000-gallons per truck. Upon entry to the WWTP, the pH of each load of septage is tested, and is accepted if within parameters. If the pH is greater than 10.0, a toxic screen procedure is performed to determine the presence of Adenosine triphosphate (ATP). The assumption is made that if ATP is present, living organisms must be present in the sample and therefore it is not toxic. The WWTP is a gravity flow system with 20 lift stations (LS) (Identified in Table 1 below). Note: Regarding numerical identification with respect to the LSs; according to information provided by Farmington, in the previous 30-years there have not been any LSs associated with #4, #6 and/or #10. The previous LS #7 was decommissioned approximately 10-years ago by back-filling and bypassing. The lift stations are equipped with standby generators and automatic switchovers in the event of power loss. The generators are exercised monthly to verify system readiness. In the event of a local power outage, an emergency generator at the headworks is available to operate the main lift station in the facility. This 2 City of Farmington/Farmington Wastewater Treatment Plant NPDES permit No. NM0020583 Inspection Date April 14, 2025 enables the WWTP to continue the treatment process through gravity flow, unabated. The WWTP receives the septage at the headworks of the treatment plant outside the main WWTP entrance, but within the fenced perimeter. Wastewater treatment begins with the influent entering at the headworks of the plant where it is pumped up grade via the main lift station to the initial screening process. Nonorganic solids and grit from the screens are fed by conveyor into a compactor/grinder, thence to a dumpster for disposal. The influent then passes through parallel aerated grit basins for further separation of solids, where when combined with solids from the screening process are disposed of in the San Juan County Landfill. At this juncture, the influent is divided and sent to either A or B primary clarifiers. Sludge drawn from these clarifiers is pumped to primary sludge digesters #1 and #2. The supernates from the primary clarifiers are split with 25% of the flow being sent to each of two trickling filters (A and B), with the remaining 50% being routed to one (1) of two (2) Medium Rate Activated Sludge (MRAS) units. These MRAS units are approximately 17-feet deep, and the volume of each basin equates to approximately 1.3 million gallons. The MRAS is a modified racetrack, having both aerobic and anoxic zones. Flow from the MRAS is sent to the secondary clarifiers where it is combined and routed to the ultraviolet (UV) treatment building for disinfection. Treated (disinfected) effluent passes through a Parshall flume, where the discharge rate is measured with a sonic flow meter; thence routed through an enclosed pipe conduit to outfall 001 (depicted in Aerial Image #2 below) and into the San Juan River. Note: An additional detailed site specific WWTP Site Plan prepared by Animas Environmental Services is provided in Aerial Site Map Image #2 below. Aerial Image #1: Overall view of the City of Farmington's Wastewater Treatment Plant. Aerial from Google Earth maps. 3 City of Farmington/Farmington Wastewater Treatment Plant NPDES permit No. NM0020583 Inspection Date April 14, 2025 Aerial Site Map Image #2: Prepared by Animas Environmental Services 4 City of Farmington/Farmington Wastewater Treatment Plant NPDES permit No. NM0020583 Inspection Date April 14, 2025 Aerial Image #2: Overall view of the City of Farmington's Wastewater Treatment Plant outfall 001. Aerial from Google Earth maps. Table 1: City of Farmington Lift Stations Lift Station Number 1 2 3 5 8 9 11 12 13 14 15 16 17 18 19 20 21 22 23* 24* 26 27 28 Location by Street Address 1395 S Lake St. 1102 S Lorena Ave 397 W Murray Dr Bisti Hwy at San Juan River 1698 W Murray Dr 91 Meadow View Dr Next to 1100 La Plata Hwy 1201 Mosseycup Drive 2995 La Habra St. 901 N Auburn Ave 157 S Orchard Ave 2105 San Juan Blvd-Only for on-site bathroom 5800 College Blvd 330 Sunrise Pkwy 4923 Primavera Dr 5301 Lauren St 1801 Andrea Dr 2409 W Pion Hills Blvd 2301 W Pion Hills Blvd 2301 W Pion Hills Blvd 41 Road 5568- McGee Park Private Lift Station 135 N Browning Pkwy- Nature Center Lift Station 6536 Club House Dr- Sandstone Subdivision LS-abandoned 5 City of Farmington/Farmington Wastewater Treatment Plant NPDES permit No. NM0020583 Inspection Date April 14, 2025 Note*: Lift Station-23 and Lift Station-24 (LS-23 and LS-24) located at 2301 W Pion Hills Blvd. are two individual single wet-well stations that collect from different areas of the sports complex, thence pump to Lift Station-22 (LS-22) (2409 W Pion Hills Blvd.) Currently there is one (1) established Industrial User (IU) that currently has entered into individual wastewater discharge agreements for disposal of their effluent into the City's WWTP (identified in Table 2 below). Table 2: City of Farmington Industrial Users Name ALSCO Address 511 East Cedar Permit Number 1002 Discharge Volume (Gallons per Day) 43,000 Effective Dates 07/01/2022 thru 06/30/2026 Additionally, Farmington has implemented written policies and procedures to address any potential sanitary sewer overflow events (SSOs), and standard operating procedures (SOPs) pertaining to facility operations and maintenance (O&M). Furthermore, by City Ordinance, a Fats, Oils and Grease (FOG) program was enacted with respect to existing and/or new FOG contributors. Section II - OBSERVATIONS I observed the following and/or the following information was provided or stated: A review of the City of Farmington completed CMOM Self-Assessment: General Information (page 2)- indicates a service area of approximately 34 square miles with an average daily flow of 4.3 MGD. A review of the City of Farmington completed CMOM Self-Assessment: Collection System Information (page 3)- indicates 23 lift or pump station (identified above), and 235-miles of gravity sewer lines. The systems piping material is comprised of polyvinyl chloride (PVC) (~43%), vitrified clay pipe (~55%) and high-density polyethylene (HDPE) the remaining (~3%). A review of the City of Farmington completed CMOM Self-Assessment: Engineering Design (ED) (page 6)- indicates new pipe installs are camera'd. Repairs are camera'd if necessary. Construction inspectors are on site documenting all work (ED-04). A review of the City of Farmington completed CMOM Self-Assessment: Organizational Structure (OC) (page 9)- indicates 3% of the staff positions are currently vacant (OC-04) and 100% of the utility work is contracted out (OC-06). A review of the City of Farmington completed CMOM Self-Assessment: Budgeting (BUD) (page 11)- indicates user charges are evaluated and adjusted annually (BUD-02). It is further indicated the maintenance budget is allotted to predictive maintenance (4%), preventive maintenance 6 City of Farmington/Farmington Wastewater Treatment Plant NPDES permit No. NM0020583 Inspection Date April 14, 2025 (32%), corrective maintenance (32%) and emergency maintenance (32%) (BUD-09), though it also indicates, " These expenditures are not divided into these categories". A review of the City of Farmington CMOM Self-Assessment: Training (TR) (page 13 and page 14) indicates most of the training (80%) is on-the-job (OJT), while the remainder is either industry wide (10%) or in-house classroom (10%) training. A review of the City of Farmington CMOM Self-Assessment: Safety (SAF) (page 13 and page 14) indicates safety procedures are reviewed and revised Annually, unless there are changes in procedures, new tasks, or employees need for additional training (SAF-02). Additionally, the utility Safety committee is being spun back up in 2025 (SAF-03). A review of the City of Farmington completed CMOM Self-Assessment: Equipment & Collection System Maintenance (ESM) (page 18) indicates the corrective repair work orders are not backlogged more than six months (ESM-06). A review of the City of Farmington completed CMOM Self-Assessment: Equipment Parts Inventory (EPI) (page 19) indicates the utility does not maintain a stock of spare parts on its maintenance vehicles (EPI-05). A review of the City of Farmington completed CMOM Self-Assessment: Management Information System (MIS) (page 20) indicates the city, does have a MIS in place for tracking maintenance activities, though various aspects under MIS-04 (page 20) are lacking in the areas of compliant work orders and customer service. A review of the City of Farmington completed CMOM Self-Assessment: Internal TV Inspection (TVI) (page 23 and page 24) indicates the CIP Division has developed an in-house pipeline condition assessment program that is utilized to develop current-year and 5-year replacement plans (TVI-01). Additionally, the CMOM indicates a rating system is used for manholes, though no rating system exists for sewer pipes - that information is relayed via email observation (TVI05). Furthermore, it also indicates the percent of the total defects determined by TV inspection, during the past 5, years were attributed to the following: debris/grease/roots (95%), intruding/roots (80%), and sag in line/grease/debris (70%) as the most severe (TVI-07). A review of the City of Farmington completed CMOM Self-Assessment: Sewer Cleaning (CLN) (page 25 and page 26) indicates that 40% percent of the total cleaning was considered repeat and trouble spot cleaning during the past year (CLN-04). Additionally, the CMOM indicates it's extremely rare to find the cause of stoppage due to rodding/cleaning, breaking up, or pushing through the stoppage within the sewer pipe (CLN-10) and video is taken after cleaning (CLN11). A review of the City of Farmington completed CMOM Self-Assessment: Manhole Inspection and Assessment (MAN) (page 26) indicates that approximately 42% (2,377) of the total manholes (5,611) were inspected during the past year (MAN-04). Additionally, the CMOM indicates the 7 City of Farmington/Farmington Wastewater Treatment Plant NPDES permit No. NM0020583 Inspection Date April 14, 2025 technicians include any abnormal conditions encountered in the notes section for manhole inspections (MAN-05). A review of the City of Farmington completed CMOM Self-Assessment: Pump Stations (PS) (page 28 and page 29) indicates that 60% of the 22 pump stations have backup power sources (PS-05), and there is not a procedure for manipulating pump operations during wet weather to increase in-line storage of wet weather flows (PS-07). Additionally, it is indicated an average of 480 labor hours are spent on pump station inspections annually (PS-14), 90% of have pump capacity redundancy (PS-15), while 25% are equipped with permanent flow meters (PS-19). A review of the City of Farmington completed CMOM Self-Assessment: Capacity Assessment (CA) (page 30) indicates that the City has some flow metering in specific locations and for specific functions - but not for the entire system (CA-01), and the City does not have a comprehensive capacity assessment and planning program (CA-02). Additionally, the CMOM indicates the City is currently developing a hydraulic model for assessing whether adequate capacity exists in the sewer system(CA-04). A review of the City of Farmington completed CMOM Self-Assessment: Tracking SSOs (TRK) (page 32 and page 33) indicates the city, has reported 15 SSO events in the past 5 years (TRK01) and 5% of the reported SSOs were less than 1,000 gallons (TRK-02). Additionally, the CMOM indicates none were at the same location (TRK-05), but of the reported SSO events manholes (6), main and trunk sewers (4) and lateral and branch sewers (5) (TRK-06) were identified. The completed CMOM also indicates the causes of the SSO discharges were construction (1), unknown (6), debris/grease (4), sag in line (1) and manhole/surcharged (1), surcharges or precipitation 1 each TRK-07). A review of the City of Farmington completed CMOM Self-Assessment: Overflow Emergency Response (OERP) indicates the city does have a documented OERP available for utility staff to use, though specific responsibilities for personnel who respond to emergencies are not detailed (OERP-03 During the closing conference, David Esparza discussed the requested completion of the Capacity, Management, Operation and Maintenance (CMOM) Self-Assessment document. Section III - SUMMARY/AREAS OF CONCERN A review of the of the CMOM self-assessment completed by the City of Farmington, and additional supporting information, indicates some of the following or could be beneficial: A review of the City of Farmington completed CMOM Self-Assessment indicates the city, has reported 15 SSO events in the past 5 years and 5% of the reported SSOs were less than 1,000 gallons. Additionally, the CMOM indicates none were at the same location, but of the reported SSO events manholes (6), main and trunk sewers (4) and lateral and branch sewers (5) were identified. The completed CMOM also indicates the causes of the SSO discharges were construction (1), unknown (6), debris/grease (4), sag in line (1) and manhole/surcharged (1), 8 City of Farmington/Farmington Wastewater Treatment Plant NPDES permit No. NM0020583 Inspection Date April 14, 2025 surcharges or precipitation 1 each. Preparation of an Overflow Emergency Response (OERP) plan delineating specific utility staff responsibilities to responding emergencies, a public notification plan and procedures to limit public contact with areas affected by sanitary sewer overflow (SSO) events. Preparation of an Internal TV Inspection (TVI), Sewer Cleaning (CLN), Manhole Inspection and Assessment (MAN) program. Preparation/creation of supporting documentation to complement the tracking maintenance activities within the existing Management Information System (MIS). Preparation of an Equipment & Collection System Maintenance (ESM) and Equipment Parts Inventory (EPI) program. Given the recent experiences of supply chain delays, it is paramount to day-to-day operations and permit compliance. Section IV - FOLLOW UP The following information and/or clarification was received by EPA after exiting on April 14, 2025: Completed Capacity Management Operations and Maintenance Self-Assessment Section V - LIST OF APPENDICES Appendix 1 - Capacity Management Operations and Maintenance Self-Assessment 9 City of Farmington/Farmington Wastewater Treatment Plant NPDES permit No. NM0020583 Inspection Date April 14, 2025 Appendix 1 City of Farmington Capacity Management Operations And Maintenance (CMOM) Self-Assessment 1 CAPACITY, MANAGEMENT, OPERATION AND MAINTENANCE (CMOM) Program Self-Assessment Compiled By: Name: ________________________________ Title: _________________________________ Date: _________________________________ Staffing list and Organization chart: Attach separate document as needed 2 General Information Service area 34 SQ. MILES Service population 50,000 PEOPLE Annual precipitation 8 inches* NUMBER *Find your annual New Mexico precipitation here: https://wrcc.dri.edu/summary/Climsmnm.html # of Treatment Facilities 1 WWTP design capacity 6.67 NUMBER MGD Average Daily Flow Manholes 4.32 MGD 5,611 NUMBER Average dry weather flow Number of air vacuum relief 2 valves 4.32 MGD NUMBER Service Area Characteristics Residential Industrial Multi-Family Total 13,001 1 N/A NUMBER Commercial Institutional Other 14,848 NUMBER 1,843 N/A 3 NUMBER Collection system service lateral responsibility (check one) At main line connection only X From main line to property line or easement/cleanout Beyond property line/clean out Other: Comments: What percent of sewer system is served by combined sewers (i.e., sanitary sewage and storm water in the same pipe)? 0 PERCENT 3 Collection System Information Conveyance & Pumping Gravity Sewers Pipes and pumps: 235 Length/quantity MILES Age of system: 0-25 years old N/A PERCENT 26-50 years old N/A PERCENT 51-75 years old N/A PERCENT >75 years old N/A PERCENT Number of Inverted N/A siphons Pump Stations Stations Force Mains 23 NUMBER 12 MILES N/A NUMBER N/A PERCENT N/A NUMBER N/A PERCENT N/A NUMBER N/A PERCENT N/A N/A NUMBER PERCENT Vacuum Stations Stations Vacuum Lines Force Mains N/A NUMBER N/A MILES N/A MILES N/A NUMBER N/A PERCENT N/A PERCENT N/A NUMBER N/A PERCENT N/A PERCENT N/A N/A NUMBER PERCENT N/A PERCENT N/A N/A NUMBER PERCENT N/A PERCENT NUMBER Pipe Diameter Information 8 inches or less 9 - 14 inches 15 - 36 inches Comments: > 36 inches Gravity Sewers 84.2 PERCENT Force Mains 57 PERCENT Vacuum Lines N/A PERCENT 7.9 PERCENT 37.4 PERCENT N/A PERCENT 7.9 PERCENT 5.6 PERCENT N/A PERCENT 0 PERCENT 0 PERCENT N/A PERCENT 4 Pipe Material Information Prestressed concrete cylinder pipe (PCCP) High density polyethylene (HDPE) Reinforced concrete pipe (RCP) Polyvinyl Chloride (PVC) Vitrified Clay Pipe Cast Iron Pipe (CIP), Ductile Iron Pipe (DIP) Non-reinforced concrete pipe Asbestos cement pipe Brick Fiberglass Cured in Place Fold and Form Comments: Gravity Sewer 0 PERCENT 0.3 PERCENT 1.5 PERCENT 42.7 PERCENT 55.1 PERCENT 0.4 PERCENT 0 PERCENT 0 PERCENT 0 PERCENT 0 PERCENT 0 PERCENT 0 PERCENT Force Mains 0 PERCENT 49.6 PERCENT 0 PERCENT 48.3 PERCENT 0 PERCENT 2.1 PERCENT 0 PERCENT 0 PERCENT 0 PERCENT 0 PERCENT 0 PERCENT 0 PERCENT Vacuum Lines N/A PERCENT N/A PERCENT N/A PERCENT N/A PERCENT N/A PERCENT N/A PERCENT N/A PERCENT N/A PERCENT N/A PERCENT N/A PERCENT N/A PERCENT N/A PERCENT 5 Engineering Design (ED) ED-01 Checklist Item Is there a document which includes design criteria and standard construction details? Comments: City of Farmington Construction Specifications Yes No N/A X ED-02 Is there a document that describes the procedures that the utility follows in construction design review? X Comments: Construction standards ED-03 ED-04 ED-05 ED-06 Are WWTP and O&M staff involved in the design review X process? Comments: Is there a procedure for testing and inspecting new or rehabilitated system elements both during and after the X construction is completed? Comments: New pipe installs are camera'd. Repairs are camera'd if necessary. Construction inspectors are on site documenting all work done. Are construction sites supervised by qualified personnel (such as professional engineers) to ascertain the construction is in accordance with the agreed upon plans and specifications? X Comments: Are new manholes tested for inflow and infiltration? X Comments: I&I is not typically an issue seen in this area. ED-07 ED-08 Are new gravity sewers checked using closed circuit TV inspection? Comments: Does the utility have documentation on private service lateral design and inspection standards? Comments: X X ED-09 Does the utility attempt to standardize equipment and sewer system components? X Comments: Comments: 6 Satellite Communities and Sewer Use Ordinance (SUO) Checklist Item SUO-01 Does the utility receive flow from satellite communities? IF NO, GO TO NEXT SECTION Comments: Yes No N/A X SUO-02 What is the total area from satellite communities that contribute flow to the collection system? (Acres or square miles) Comments: SUO-03 Does the utility require satellite communities to enter into an agreement? IF NO, GO TO QUESTION SUO-06 Comments: SUO-04 Does the agreement include the requirements listed in the sewer use ordinance? Comments: SUO-05 Do the agreements have a date of termination and allow for renewal under different terms? Comments: SUO-06 Does the utility maintain a legal authority to control the maximum flow introduced into the collection system from satellite communities? Comments: SUO-07 Are standards, inspections, and approval for new connections clearly documented in a SUO? Comments: SUO-08 Does the SUO require satellite communities to adopt the same industrial and commercial regulatory discharge limits as the utility? Comments: SUO-09 Does the SUO require satellite communities to adopt the same inspection and sampling schedules as required by the pretreatment ordinance? Comments: SUO-10 Does the SUO require satellite communities or the utility to issue control permits for significant industrial users? Comments: 7 Checklist Item SUO-11 Does the SUO contain provisions for addressing overstrength wastewater from satellite communities? Comments: SUO-12 Does the SUO contain procedures for the following? Inspection standards Pretreatment requirements Building/sewer permit issues Comments: SUO-13 Does the SUO contain general prohibitions of the following materials? Fire and explosion hazards Corrosive materials Obstructive materials Oils or petroleum Material which may cause interference at the wastewater treatment plant Comments: SUO-14 Does the SUO contain procedures and enforcement actions for the following? Fats, oils, and grease (FOG) Infiltration and inflow Building structures over the sewer lines Storm water connections to sanitary lines (downspouts) Defects in service laterals located on private property Sump pumps, air conditioner connections Comments: Comments: Yes No N/A 8 Organizational Structure (OC) Checklist Item OC-01 Is an organizational chart available that shows the overall personnel structure for the utility, including operation and maintenance staff? Comments: Yes No N/A X OC-02 OC-03 Are up-to-date job descriptions available that delineate responsibilities and authority for each position? Comments: Are the following items discussed in the job descriptions? Nature of work to be performed Minimum requirements for the position Necessary special qualifications or certifications Examples of the type of work List of licenses required for the position Performance measures or promotion potential Comments: X X X X X X X OC-04 What percent of staff positions are currently vacant? 3 Comments: OC-05 On average how long do positions remain vacant? (months) Comments: 2 months OC-06 What percent of utility work is contracted out? Comments: 100% Comments: 9 Internal Communications (IC) Checklist Item IC-01 Which of the following methods are used to communicate with utility staff? Regular meetings Bulletin boards E-mail Cell Phones Other (explain) Comments: Additionally, texting is used Yes No N/A X X X X IC-02 How often are the staff meetings held? Weekly (e.g., Daily, Weekly, Monthly, etc.) Comments: IC-03 Are incentives offered to employees for performance improvements? X Comments: IC-04 Does the utility have an X "Employee of the Month/Quarter/Year" program? Comments: IC-05 How often are performance reviews conducted? Annually (e.g. Semi-annually, Annually, etc.) Comments: Annually IC-06 Does the utility regularly communicate/coordinate with other X municipal departments? Comments: Comments: 10 Budgeting (BUD) Checklist Item BUD-01 What is the average annual fee for residential users? $54.82/mo Comments: BUD-02 How often are user charges evaluated and adjusted? (e.g. annually, biannually. etc.) Comments: A n n u a l l y BUD-03 Are utility-generated funds used for non-utility programs? Comments: Yes No N/A X BUD-04 Are costs for collection system operation and maintenance (O&M) X separated from other utility services such as water, storm water, and treatment plants? IF NO, GO TO BUD-07 Comments: BUD-05 What is your average annual (O&M) budget? Comments: BUD-06 What percentage of the utility's overall budget is allocated to maintenance of the collection system? Comments: BUD-07 Does the utility have a Capital Improvement Plan (CIP) that provides for system repairs/replacements on a prioritized basis? X Comments: BUD-08 What is your average annual CIP budget? $4.7M Comments: Comments: 11 Checklist Item BUD-09 What percentage of the maintenance budget is allotted to the following maintenance? Predictive maintenance - 4% Preventive maintenance - 32% Corrective maintenance - 32% Yes No N/A Emergency maintenance - 32% Comments: T h e s e e x p e n d i t u r e s a r e n o t d i v i d e d i n t o these categories. BUD-10 Does the utility have a budgeted program for the X replacement of under-capacity pipes? Comments: BUD-11 Does the utility have a budgeted program for the X replacement of over-capacity pipes? Comments: There are no over-capacity pipes. Only planning for growth and expansion. Comments: 12 Training (TR) Checklist Item Yes No N/A TR-01 Does the utility have a formal job knowledge, skills, and X abilities (KSA) training program? TR-02 Comments: N e w E m p l o y e e s a f e t y o r i e n t a t i o n ( N E S O ) ; specific training for hi-rist tasks. Does the training program address the fundamental mission, X goals, and policies of the utility? Comments: Purpose & responsibilities TR-03 Does the utility have mandatory training requirements X identified for key employees? Comments: TR-04 What percentage of employees met or exceeded their annual training goals during the past year? 90% Comments: TR-05 Does the utility provide training in the following areas? Safety Routine line maintenance Confined space entry Traffic control Record keeping Electrical and instrumentation Pipe repair Bursting / CIPP Public relations SSO/Emergency response Pump station operations and maintenance CCTV and trench/shoring Other Comments: X X X X X X X X X X X X TR-06 Are operator and maintenance certification programs used? X IF NO GO TO TR-08 Comments: TR-07 Are operator and maintenance certification programs X required? Comments: For appropriate personnel. TR-08 Is on-the-job training progress and performance measured? X Comments: 13 TR-09 Checklist Items Yes No NA Which of the following methods are used to assess the effectiveness of the training? None Periodic testing X Drills X Demonstrations X Comments: TR-10 What percentage of the training offered by the utility is in the form of the following? Manufacturer training On-the-job training 80% In-house classroom training 10% Industry-wide training 10% Comments: Safety (SAF) Checklist Item Yes No N/A SAF-01 Does the utility have a written safety policy? X Comments: SAF-02 How often are safety procedures reviewed and revised? (Annually, quarterly, etc.) Comments: A n n u a l l y , u n l e s s t h e r e a r e c h a n g e s i n : p r o c e d u r e s , new task, or employee need for additional training SAF-03 Does the utility have a safety committee? X Comments: Not currently. Safety committee is being spun back up in 2025. SAF-04 Are regular safety meetings held with the utility employees? X How often? Daily POD, weekly, and as needed for specific jobs Comments: SAF-05 Does the utility have a safety training program? X Comments: Jacobs SMS SAF-06 Are records of employee safety training kept up to date? X Comments: E3 Learning platform 14 SAF-07 Checklist Item Does the utility have written procedures for the following? Lockout/tagout Material safety data sheets (MSDS) Chemical handling Confined spaces permit programs Trenching and excavations safety Biological hazards in wastewater Traffic control and work site safety Electrical and mechanical systems Pneumatic and hydraulic system safety Comments: Yes No N/A X X X X X X X X X SAF-08 What is your agency's lost-time injury rate? 0 Comments: 0 h o u r s i n 2 0 2 4 SAF-09 Are the following equipment items available and in adequate supply? Rubber/disposable gloves X Confined space ventilation equipment X Hard hats, safety glasses, rubber boots X Antibacterial soap and first aid kit X Tripods or non-entry rescue equipment X Fire extinguishers X Equipment to enter manholes Portable crane/hoist X Atmospheric testing equipment and gas detectors X Oxygen sensors X H2S Monitors X Full body harness X Protective clothing X Traffic/public access control equipment X 5-minute escape breathing devices X Life preservers for lagoons X Life preservers at activated sludge plants X Fiberglass or wooden ladders for electrical work X Respirators and/or self-contained breathing apparatus X Methane gas or optical vector (OVA) analyzer X Lower explosion limit (LEL) metering X Comments: SAF-10 Are safety monitors clearly identified? X Comments: Placards/signeage 15 Customer Service (CS) Checklist Item CS-01 Does the utility have a customer service and public relations program? IF NO GO TO CS-03 Comments: Yes No N/A X CS-02 Does the customer service program include giving formal presentations on the wastewater field to the following? Schools and universities Community gatherings Local officials Businesses Media Citizens Building Inspector(s) Public utility officials Comments: X X X X X X X X CS-03 CS-04 Are employees of the utility specifically trained in customer service? Comments: Are there sample correspondence, Q/A's, or "scripts" to help guide staff through written or oral responses to customers? Comments: X X CS-05 What methods are used to notify the public of major construction or maintenance work? Door hangers X Public radio or T.V. announcements Newspaper X Flyers Signs X Other X None Comments: F a c e B o o k i s u s e d q u i t e e x t e n s i v e l y 16 CS-06 Checklist Item Is a homeowner notified prior to construction that his/her property may be affected? Comments: CS-07 Do you provide information to residents on cleanup and safety procedures following basement backups and overflows from manholes when they occur? Comments: Yes No N/A X X CS-08 Does the utility have a customer service evaluation program to X obtain feedback from the community? Comments: Customers can report issues or problems via the City's website - CivicPlus. This captures all the submitted information. CS-09 Do customer service records include the following information? Personnel who received the complaint or request X Nature of the complaint or request X To whom the follow-up action was assigned X Date of the complaint or request X Date the complaint or request was resolved X Total days to end the problem X Name, address, and telephone number of the customer X Location of the problem X Date the follow up action was assigned X Cause of the problem X Feedback to customer X Comments: CS-10 Does the utility have a goal for how quickly customer X complaints (or emergency calls) are resolved? IF NO, GO TO NEXT SECTION Comments: Less than 24 hours CS-11 What percentage of customer complaints (or emergency calls) are resolved within the timeline goals? 90% Comments: 17 Equipment & Collection System Maintenance (ESM) Checklist Item ESM-01 Is a maintenance card or record kept for each piece of mechanical equipment within the collection system? IF NO, GO TO ESM-03 Comments: Yes No N/A X ESM-02 Do equipment maintenance records include the following information? Maintenance recommendations X Instructions on conducting the specific maintenance activity X Other observations on the equipment X Maintenance schedule X A record of maintenance on the equipment to date X Comments: ESM-03 Are dated tags used to show out-of-service equipment? X Comments: LOTO policy ESM-04 Is there an established system for prioritizing equipment X maintenance needs? Comments: ESM-05 What percent of repair funds are spent on emergency repairs? Comments: ESM-06 Are corrective repair work orders backlogged more than six X months? Comments: ESM-07 Do collection system personnel coordinate with state, county, and local personnel on repairs, before the street is paved? X Comments: W e c o o r d i n a t e w i t h C i t y T r a f f i c D e p a r t m e n t , City Outage group, and NMDOT when required. Comments: 18 Equipment Parts Inventory (EPI) EPI-01 Checklist Item Have critical spare parts been identified? Comments: Yes No N/A X EPI-02 Are adequate supplies on hand to allow for two-point repairs in X any part of the system? Comments: EPI-03 Is there a parts standardization policy in place? X Comments: EPI-04 Does the utility have a central location for storing spare parts? X Comments: EPI-05 Does the utility maintain a stock of spare parts on its X maintenance vehicles? Comments: EPI-06 Does the utility have a system in place to track and maintain an X accurate inventory of spare parts? Comments: EPI-07 For those parts which are not kept in inventory, does the X utility have a readily available source or supplier? Comments: Comments: 19 Management Information System (MIS) Checklist Item MIS-01 Does the utility have a management information system (MIS) in place for tracking maintenance activities? (Either electronic or good paper files) IF NO, GO TO NEXT SECTION Comments: Yes No N/A X MIS-02 Are the MIS records maintained for a period of at least three X years? Comments: MIS-03 Is the MIS able to distinguish activities taken in response to X an overflow event? Comments: MIS-04 MIS-05 Are there written instructions for managing and tracking the following information? (Check all that apply) Complaint work orders X Schedule work orders Customer Service X X Scheduled preventive maintenance X Scheduled Inspections X Scheduled system inventory X Safety incidents X Scheduled monitoring/sampling X Compliance/overflow tracking X Equipment/tools tracking X Parts inventory X Do the written instructions for tracking procedures include the following information? Accessing data and information X Instructions for using the tracking system X Updating the MIS X Developing and printing reports X Comments: 20 MIS-06 Checklist Item How often is the management information system updated? Yes No N/A Immediately Within one week of the "incident" Monthly Other: X Comments: Unknown - managed by corporate IT department Comments: System Mapping (MAP) Checklist Item MAP-01 Are "as built" plans (record drawings) or maps available for use by field crews in the office and in the field? Comments: MAP-02 Is there a procedure for field crews to record changes or inaccuracies in the maps and update the mapping system? Comments: Yes No N/A X X MAP-03 Do the maps show the date the map was drafted and the X date of the last revision? Comments: Comments: 21 MAP-04 Checklist Item Do the sewer line maps include the following? Scale North arrow Date the map was drafted Date of last revision Service area boundaries Property lines Other landmarks (Roads, water bodies, etc.) Manhole and other access points Location of building laterals Street names SSOs occurrences/CSOs outfalls Flow monitors Force mains Pump stations Lined sewers Main, trunk, and interceptor sewers Easement lines and dimensions Pipe material Pipe diameter Installation date Slope Manhole rim elevation Manhole coordinates Manhole invert elevation Distance between manholes Comments: MAP-05 Are the following sewer attributes recorded? Size Shape Invert elevation Material Separate/combined sewer Installation date Comments: Yes No N/A X X X X X X X X X X X X X X X X X X X X X X X X X X X X X 22 MAP-06 Checklist Item Are the following manhole attributes recorded? Shape Type (e.g., precast, cast in place, etc.) Depth Age Material Comments: Yes No N/A X X X X X MAP-07 Is there a systematic numbering and identification system to X identify manholes, sewer lines, pump station, etc.? Comments: Internal TV Inspection (TVI) Checklist Item Yes No N/A TVI-01 Does the utility have a standardization pipeline condition assessment X program? If yes, explain Comments: The CIP Division has developed an in-house pipeline condition assessment program that is utilized to develop current-year and 5-year replacement plans. TVI-02 Is internal TV inspection used to perform condition assessment? X IF NO, GO TO NEXT SECTION Comments: TVI-03 Are there written operation procedures/guidelines for the internal TV X inspection program? Comments: TVI-04 Do the internal TV record logs include the following? Pipe size, type, length, and joint spacing X Distance recorded by internal TV X Results of the internal TV inspection (including a structural rating) X Internal TV operator name X Cleanliness of the line X Location and identification of line being televised by manholes X Comments: Structural or cleanliness issues are relayed by email 23 TVI-05 Is a rating system used to determine the severity of the defects X X found during the inspection process? Comments: A rating system is used for manholes. No rating system exists for sewer pipes - that information is relayed via email observation. TVI-06 Is there a code list used for internal TV inspection reporting? X Approximately what percent of the total defects determined by TV inspection, during the TVI-07 past 5, years were attributed to the following? Debris 95% Debris/Grease 60% Debris/Roots 40% Grease 20% Grease/Roots 20% Intruding Tap 40% Intruding Tap/Roots 80% Surcharged 20% Offset Joint/Grease 70% Roots 40% Roots/Debris 40% Roots/Grease 20% Roots/Grease/Debris 30% Roots/Line Failure 20% Line Failure 15% Sag In Line 70% Sag In Line/Debris 40% Sag In Line/Grease 40% Other: Slipped taps 20% Other: Total Percentage Comments: TVI-08 Are main line and lateral repairs checked by internal TV X inspection after the repair(s) have been made? Comments: 24 Sewer Cleaning (CLN Checklist Item Yes No NA CLN-01 Is there a program to identify sewer line segments, with chronic X problems, that should be cleaned on a more frequent schedule? Comments: CLN-02 CLN-03 What is the entire system cleaning frequency? (e.g., every "X" years) Comments: What is the utility's plan for system cleaning (% or frequency in years)? Comments: 4 Years 0.25% each year CLN-04 CLN-05 CLN-06 CLN-07 CLN-08 CLN-09 What percent of the total cleaning was considered 40% repeat and trouble spot cleaning during the past year? Comments: Does the utility have a root control program? X Comments: Does the utility have a fats, oils, and grease (FOG) program? X Comments: What is the average number of stoppages experienced per 100 miles of sewer pipe per year? Comments: Information not available Has the number of stoppages increased, decreased, or stayed the same over the past 5 years? Comments: Information not available Are stoppages plotted on maps and correlated with other data X such as pipe size and material or location? Comments: Comments: CLN-10 25 Checklist Item Yes No NA Do the sewer cleaning records include the following information? Date and time X Cause of stoppage X Method of cleaning X Location of stoppage or routine cleaning activity X Identity of cleaning crew X Further actions necessary/initiated X Comments: Extremely rare to find cause of stoppage due to rodding/cleaning, breaking up, or pushing through cause within the sewer pipe CLN-11 If sewer cleaning is done by a contractor, are videos taken before and after cleaning? Comments: Video is taken after cleaning. X X Manhole Inspection and Assessment (MAN) Checklist Item MAN-01 Does the utility have a routine manhole inspection and assessment program? IF NO, GO TO MAN-06 Comments: Yes No N/A X MAN-02 Are the results and observations from the routine manhole X inspection recorded? Comments: MAN-03 MAN-04 Does the utility have a goal for the number of manholes X inspected annually? Comments: How many manholes were inspected during the past year? 2,377 What is the percent of total manholes were inspected during the 42.2% past year? Comments: Comments: 26 MAN-05 Checklist Item Yes No N/A Do the records for manholes/pipe inspection include the following? Conditions of the frame and cover X Evidence of surcharge X Offsets or misalignments X Atmospheric hazards measurements (especially hydrogen X sulfide) Details on the root cause of cracks or breaks in the X manhole or pipe including blockages Recording conditions of (corbel, walls, bench, trough, and X pipe seals) Presence of corrosion X If repair is necessary X Manhole identifying number/location X Wastewater flow characteristics (flowing freely or backed X up) Accumulation of grease, debris, or grit X Presence of infiltration, location, and estimated quantity X Inflow from manhole covers X Comments: In the notes section for manhole inspections, techs include any abnormal conditions encountered. MAN-06 Does the utility have a grouting program? X Comments: Comments: 27 Pump Stations (PS) Checklist Item PS-01 Are Standard Operating Procedures (SOPs) and Standard Maintenance Procedures (SMPs) used for each pump station? Comments: Yes No N/A X PS-02 Are there enough trained personnel to properly inspect and X maintain all pump stations? Comments: PS-03 Is there an emergency operating procedure for each pump X station? Comments: PS-04 Is there an alarm system to notify personnel of pump station X failures and overflow? Comments: PS-05 Percent of pump stations with backup power sources 60% Comments: PS-06 Does the utility use the following methods when loss of power occurs? On-site electrical generators X Portable electric generators X Vacuum trucks to bypass pump station X Alternate power source X Other Comments: PS-07 Is there a procedure for manipulating pump operations during X wet weather to increase in-line storage of wet weather flows? Comments: Comments: 28 Checklist Item PS-08 Are wet well operating levels set to limit pump start/stops? Comments: Yes No N/A X PS-09 Are the lead, lag, and backup pumps rotated regularly? X Comments: PS-10 Are operation logs maintained for all pump stations? Comments: PS-11 Are the manuals that contain the manufacturers recommended maintenance schedules for all pump station equipment available? Comments: PS-12 On average, how often were pump stations inspected during the past year? Comments: PS-13 Are records maintained for each inspection? Comments: X X Weekly X PS-14 Average annual labor hours spent on pump station inspections Comments: PS-15 Percent of pump stations with pump capacity redundancy Comments: PS-16 Percent of pump stations with dry weather capacity limitations Comments: PS-17 Percent of pump stations with wet weather capacity limitations Comments: 480 90% Unknown Unknown PS- Percent of pump stations calibrated annually 0 18 Comments: PS- Percent of pump stations with permanent flow meters 25% 19 Comments: 29 Capacity Assessment (CA) Checklist Item Yes No N/A CA-01 Does the utility have a flow monitoring program? X Comments: The utility has some flow metering in specific locations and for specific functions - but not for the entire system. CA-02 Does the utility have a comprehensive capacity assessment X and planning program? Comments: CA-03 Are flows measured prior to allowing new connections? X Comments: CA-04 Do you have a tool (hydraulic model, spreadsheet, etc.) for X assessing whether adequate capacity exists in the sewer system? IF NO, GO TO CA-06. Comments: The hydraulic model is currently in process of being developed and built. CA-05 Does your capacity assessment tool produce results consistent with conditions observed in the system? Comments: CA-06 What is the ratio of peak wet weather flow to average dry weather flow at the wastewater treatment plant? Comments: 2.2 - 1.0 CA-07 How many permanent flow meters are currently in the system? 5 (Include meters at pump stations and WWTPs) Comments: CA-08 CA-09 How frequently are the flow meters checked? Comments: Do the flow meter checks include the following? Independent water level Checking the desiccant Velocity reading Cleaning away debris Downloading data Battery condition Monthly 30 Comments: Checklist Item Yes No N/A CA-10 Are records maintained for each inspection? IF NO, GO TO CA-12 X Comments: CA-11 Do the flow monitoring records include the following? Descriptive location of flow meter Type of flow meter Frequency of flow meter inspection Frequency of flow meter calibration Comments: CA-12 Does the utility maintain any rain gauges? X Comments: CA-13 Does the utility have any wet weather capacity problems? X Comments: CA-14 Are low points or flood-plain areas monitored during rain events? X Comments: CA-15 Does the utility have any dry weather capacity problems? X Comments: CA-16 Is flow monitoring used for billing purposes, capacity analysis, X and/or inflow and infiltration investigations? Comments: 31 Comments: Tracking SSOs (TRK) TRK-01 Checklist Item How many SSO events have been reported in the past 5 years? Comments: Yes No N/A 15 TRK-02 What % of SSOs were less than 1,000 gallons in the past 5 years? 5 Comments: TRK-03 Does the utility document and report all SSOs regardless of size? X Comments: TRK-04 Does the utility document basement backups? X Comments: TRK-05 Are there areas that experience frequent street flooding? X Comments: N o n e a r e r e c c u r i n g i n s a m e l o c a t i o n TRK-06 32 What % of SSO discharges were from each of the following in the last 5 years? Manholes 6 Lift/Vacuum Systems (Revised term) Main and trunk sewers 4 Lateral and branch sewers 5 Total 15 Comments: TRK-07 Checklist Item Yes No N/A What % of SSO discharges were caused by each of the following in the last 5 years? Construction 1 Cause Unknown 6 Debris 3 Debris/Grease 1 Debris/Roots Equipment Failure Grease Sag In Line 1 Intruding Tap Line Failure Manhole/Surcharged 1 Offset Joint Roots Roots/Debris Roots/Grease Roots/Intruding Tap Roots/Line Failure Surcharged 1 Other(s): Precipitation 1 Grand Total Comments: TRK-07A Checklist Item What percentage of SSOs were released to: Storm Sewer Arroyo/Ditch/Drain Street/ Parking lot 4 1 4 33 Private Property 1 River/Stream/Lake/Bayou/Ocean Other: 2 Grand Total 3 Comments: TRK-07B For surface water releases, what percent are to areas that could affect: Contact recreation (beaches, swimming areas) 0% Drinking water sources 0% Shellfish growing areas 0% Fishing or spawning areas 0% Comments: TRK-08 Checklist Item How many chronic SSO locations are in the collection system? Comments: Yes No N/A None TRK-09 Are pipes with chronic SSOs being monitored for sufficient X capacity and/or structural condition? Comments: TRK-10 Prior to collapse, are structurally deteriorating pipelines being X monitored for renewal or replacement? Comments: Comments: Overflow Emergency Response (OERP) Checklist Item OERP-01 Does the utility have a documented OERP available for utility staff to use? IF NO, GO TO OERP-04 Comments: OERP-02 How often is the OERP reviewed and updated? (Annually, Biannually, etc.) Yes No N/A X As needed 34 Comments: OERP-03 Are specific responsibilities detailed in the OERP for personnel X who respond to emergencies? Comments: OERP-04 Are staff continuously trained to respond to emergencies? X Comments: OERP-05 Do work crews have immediate access to tools and equipment X during emergencies? Comments: OERP-06 Checklist Item Yes No N/A Does the utility have procedures for notifying state agencies, local health departments, the NPDES authority, the public, and drinking water X authorities of significant overflow events? Comments: OERP-07 Does the procedure include a current list of the names, titles, phone X numbers, and responsibilities of all personnel involved? Comments: OERP-08 Does the utility have a public notification plan? X Comments: OERP-09 Does the utility have procedures to limit public contact with areas X affected by SSOs? (can be delegated to another authority) Comments: OERP-10 Does the utility use containment techniques to protect storm systems? X Comments: OERP-11 Do the overflow records include the following information? Date and time X 35 Cause(s) X Names of affected receiving water(s) X Location X How it was stopped X Any remediation efforts X Estimated flow/volume discharged X Duration of overflow X Comments: OERP-12 Does the utility have signage to keep public from affected area? X Comments: Smoke & Dye Testing (SDT) Checklist Item SDT-01 Does the utility have a smoke testing program to identify sources of inflow and infiltration? Comments: I & I i s n o t a k n o w n i s s u e i n t h i s a r e a . utility does not do smoke testing. Yes No N/A X The SDT-01A Does the utility have a smoke testing program to identify sources of X inflow and infiltration in illegal connectors? Comments: SDT-01B Does the utility have a smoke testing program to identify sources of X inflow and infiltration in house laterals (private service laterals)? Comments: SDT-02 Are there written procedures for smoke testing? X Comments: SDT-03 Is there a documented procedure for isolating line segments? X Comments: 36 SDT-04 Is there a documented procedure for notifying residents that smoke X testing will be conducted in their area? Comments: Comments: SDT-05 Checklist Item What is the guideline for maximum amount of line to be tested at one time? (Feet or Miles) Comments: SDT-06 Are there guidelines for the weather conditions under which smoke testing should be conducted? Comments: SDT-07 What is the goal for the % of the system smoke tested each year? Comments: Yes No N/A X X X SDT-08 What % of the system has been smoke tested in the past 5 years? Comments: SDT-09 Do the written records contain location, address, and description of the smoking element that produced a positive result? Comments: SDT-10 Does the utility have a dye testing program? Comments: SDT-11 Are there written procedures for dye testing? Comments: N/A X X X SDT-12 Does the utility have a goal for the percent of the system dye X tested each year? 37 Comments: SDT-13 What percent of the main collection system had been dye tested over the past year? Comments: Less than 2%. It is done only when necessary to resolve unknown situations SDT-14 Does the utility share smoke and dye testing equipment with X another utility? Comments: Comments: Hydrogen Sulfide Monitoring and Control (HSMC) Checklist Item Yes No N/A HSMC-01 How would you rate the system vulnerability for hydrogen sulfide corrosion? Not a problem Only in a few isolated areas X A major problem Comments: HSMC-02 Does the utility have a corrosion control program? Comments: HSMC-03 Does the utility take hydrogen sulfide corrosion into consideration when designing new or replacement sewers? Comments: X X HSMC-04 Does the utility have procedures for application of chemicals? Comments: HSMC-05 Are the chemical dosages, dates, and locations documented? Comments: X X 38 HSMC-06 Does the utility document where odor is a problem in the system? X Comments: HSMC-07 Does the utility have a program in place for renewing or replacing severely corroded sewer lines to prevent collapse? X Comments: Comments: HSMC-08 Checklist Item Are the following methods used for hydrogen sulfide control? Aeration Iron Salts Enzymes Activated charcoal canisters Chlorine Sodium hydroxide Hydrogen peroxide Potassium permanganate Biofiltration Other Comments: Yes No N/A X X X X X X X X X HSMC-09 Does the system contain air relief valves at the high points of X the force main system? Comments: HSMC-10 How often are the valves maintained and inspected? X (Weekly, Monthly, etc.) 39 Comments: HSMC-11 Does the utility enforce pretreatment requirements? X Comments: Comments: Infrastructure Security Although outside the scope of a CMOM program, municipal wastewater utilities should also consider security vulnerabilities. To reduce the threat of both intentional and natural disasters, the utility should take steps to implement appropriate countermeasures and develop or update emergency response plans. Please summarize any program the utility has for infrastructure security. All sites - lift stations, pump stations, and plants have security fencing. Plants have 24 hour coverage with cameras. 40 Comments: