Turning a Negative into a Positive Negotiating a Consent Decree to Develop a Reasonable Endpoint

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Turning a Negative into a Positive Negotiating a Consent Decree to Develop a Reasonable Endpoint City of Haverhill s Story Mr. James Drake Mr. Robert Ward, Deputy Superintendent of Public Works, Haverhill Mr. Paul Jessel, Collection System Supervisor, Haverhill January 19, 2017

Agenda A little about Haverhill Compliance history EPA directive Negotiations Progress thus far Financial impacts Conclusions

City of Haverhill 62,000 people 36 square miles Urban and rural mix septic on the outskirts of the city 18% combined sewer Old Mill City on the Merrimack River

Wastewater Treatment Plant 18 mgd average day flow 60 mgd wet-weather peak flow Built in late 1970 s Collection System 37 pumping stations 187 miles of pipe 6 to 66 inch pipe 13 Combined sewer overflows/15 CSO regulators 3 Merrimack river siphon crossings Late 1800 s 26 Staff $9.4 million annual budget including stormwater

Stormwater 100 miles of pipe 9,000 catch basins 1,200 outfalls Detention basins, other structures, etc. Street sweeping and catch basin cleaning

Haverhill s challenges NOW! Consent decree compliance Aging treatment plants (water and wastewater) Combined Sewer Overflows (CSO s) Aging Wastewater Collection System and Water Distribution System Stormwater Permit and infrastructure Increased O & M for everything Staffing Landfill closure Water Treatment How do we get it all done? How do we pay for all this?

Wastewater Compliance History August 2002 Final Phase I LTCP August 2002 to 2007 Phase I Implementation September 15, 2008/February 9, 2009 Administrative Order Complete Phase II LTCP Also covered Stormwater/CMOM July 2011 Phase II LTCP 2013 Initial USEPA/MADEP comments on the Phase II Plan 2013 City increased plan in response to comments February 2014 Department of Justice notification of pending Consent Decree Negotiations City signed in February 2016 Effective date of November 2017

Consent Decree Requirements Planning Flow metering (CSOs) Treatment Plant comprehensive evaluations, HFM, and O&M Manual Collection System (CMOM, SSO s, etc.) Combined Sewer Overflows (CSO s) Final Long Term Control Plan (LTCP) MS4 Permit Compliance (Dry weather outfall inspections, IDDE, and testing/ordinances) Staffing Assessment Administrative Requirements GIS, reporting, etc. Supplemental Environmental Project (stream bank restoration) Construction - CSO Plant improvements (sludge dewatering and odor improvements) Collection system improvements $13 million ongoing

Consent Decree Deliverables and Status Planning requirements will result in submittals to EPA and DEP with capital improvements and schedules Wastewater Treatment Plant CSO Collection System (CMOM/Asset Assessment) Integrated Wastewater Division Capital Plan All due on January 31, 2017 The capital improvements and schedules will become enforceable under the consent decree!!! Costs are unknown right now

What was the plan? Submit plans and schedules as required by the consent decree that make sense for Haverhill while maintaining compliance with the consent decree and the myriad of regulations Look at everything and identify what needs to be done Develop criteria for prioritizing needs Develop CIP balance needs and funds available Consider other DPW/City priorities

How was the work completed? Staffing Management Technical O&M Consultants and contractors Technology Better information for decision making More effective use of staff Tools for staff (MaintStarCMMS)

Findings - Comprehensive WWTP Evaluation Building/Equipment and Process Assessment Issues Aging equipment (some has been replaced in 2002 and 2016 WWTP Upgrades) Good process Odors (primarily addressed by new centrifuges and miscellaneous upgrades around plant; future program to look at larger/more expensive upgrades) NPDES Exceedance BOD, TSS, Bacteria (Enterococci) Historic and old (past upsets and solids issues) More recent data is a dramatic improvement City is implementing enhancements to IPP and FOG Need to focus on bacteria Priorities Aeration system needs upgrading to ensure adequate treatment Enterococci

Findings CMOM/Collection System Capital Renewal CCTV and Assessment 10 percent of system inspected by CCTV to assess rehabilitation needs and develop screening and sewer rehab program Three discrete I/I programs that identified sewer rehab improvements Recommendation to continue program of cleaning and inspection and complete identified pipe rehabilitation (subcontracted) SSOs Average of 21 per year, mostly attributed to temporary sewer blockages/pump station maintenance City enhanced reporting to meet EPA requirements Will improve sewer cleaning/response (cameras to investigate) Increased attention to preventive maintenance at pump stations and collection system (replace as necessary) Formal staff training

Findings - Staffing Plan Available resources were compared to other similar plant staffing Staffing plan assessed using industry guidelines A staffing shortfall is noted and the impact of retirements on institutional knowledge Succession planning and training should be addressed Mix of outsourced activities and new hires to address organizational needs Temporary use of contracted staff to complete some maintenance issues and free up staff to concentrate on preventive maintenance Key new hires targeted with a slight re-organization of responsibilities with a focus on staffing for Maintenance at the WWTP Asset management, regulatory reporting, capital programs oversight

Findings Final LTCP Haverhill Progress since 2002 Closed more than 13 outfalls Increased WWTP wet weather capacity from 46 mgd to 60 mgd Raised Weirs Modified four regulators with new improvements in 2016 and will implement real-time control in 2017 Result - Reduced CSO discharges from 70 MG to 20 MG (March 2017) Final LTCP Updated SWMM Model with permanent CSO gauge information Updated areas with new stormwater outfall/piping system information Modeled a range of CSO abatement design control levels 3 Month Control Plan was selected as the control plan

Final LTCP Components Name NPDES ID Current (March 2017) Volume (MG) Events 3-Month Control Plan Volume (MG) Events Wet Weather System Controls Optimization Conveyance improvements (cleaning) Dry-weather connection pipe modifications Green Infrastructure demonstration program Locke Street Area Improvements Sewer separation or storage facilities ~$16 million Will result in reduction of CSOs to 11 MG and 4 times per year (1 CSO regulator out of 15; the result are less than 4 times per year) Upper Siphon CSOs Upper Siphon 024 0.9 4 0.7 2 Middle Siphon CSOs Winter Street 021G 0.3 1 Winter & Hale 021H 0.9 9 Locke Street Center Barrel 021F 8.0 22 4 4 Broadway (flood) 037 High Street (flood) 038 Emerson (flood) 021B Middle Siphon 021A 3.1 5 2 3 Lower Siphon CSOs Main St North 019 0 0 Bethany Avenue 040 0.9 17 0.6 0.4 Chestnut Street 041 0.8 15 0.4 3 Lower Siphon 013 3 4 1.9 3 Bradford CSOs Bradford 032 0 0 Middlesex Street 034 0.8 10 0.5 2 South Webster Street 039 0.9 34 0.5 0.8 TOTAL 19.6 10.6

Integrated Wastewater Division Capital Plan Phase I WWTF Improvements ~$19 million Secondary Treatment Disinfection Investigations and Enhancements CMOM Program Enhancements ~9 million Pipe cleaning and inspections Pump station renewals System rehabilitation CSO Control Program ~16 million Stormwater Program ~5.5 million SEP Program ~0.9 million Total of ~50 million

Other Regulatory Responsibilities Landfill to be closed $8 million spent Downtown flood protection system (wall, pump station and Little River conduit) FEMA $5 million spent

Other Priorities - Drinking Water System Treatment Plant 12 mgd 12 pumping stations Built in late 1970 s Storage Tanks Surface water, Reservoir Distribution System 300 miles of pipe 1,636 Hydrants Late 1800 s $8.1 million annual budget

Within 1 to 2 years Landfill $13.4 million Water Treatment Plant $35 million 20 & 36 Water Transmission Main $ 5 million Stormwater Permit $1.1 million/year These costs do not include money already spent on CSO, stormwater, WWTP NPDES, landfill, etc.

Funding Sources? Financial planning SRF User rates Retained earnings Grants

2016 Wastewater Budget $1,631,207 $756,000 $3,009,547 Employees Expenses $372,508 Stormwater Debt Capital $3,659,414 The ongoing WWTP and Phase II CSO work will add $874,000 to the annual debt payment. The proposed Integrated Wastewater Division Plan will add even more.

Water and Wastewater Rates 2017 is the proposed rate $6.00 $5.00 $4.00 $3.00 $2.00 $1.00 $0.00? Future rate increases? Water Wastewater Fiscal Year

Conclusions Take a step back from the allegations Look proactively to identify issues and address problems Once the issues were aired, we worked collaboratively with DOJ, US Attorneys, MA Attorneys, USEPA and MADEP Negotiated reasonable deliverables and schedules Realigned report deliverables Scrutinized scope to make sure that it wasn t overreaching Prepared a delivery schedule to fit into city s funding protocols and time periods Engaged lawyers to help write the language/negotiate Integrated the Consent Decree efforts into a positive assessment of the city s assets for future planning

Thank you! Questions?

Contact us! Mr. Jim Drake, P.E. 603-222-8336 DrakeJS@cdmsmith.com Find more insights through our water partnership at cdmsmith.com/water and @CDMSmith