HomeMy Public PortalAboutAnnual Report Supplement, January 1 to December 31, 20191 E--:1 11
Metropolitan St. Louis
Sewer District
2351 Market Street
St, Louis, MD 63103-2555
Phone: 314.768.6200
thew vr.st[ nsd.corn
December 10, 2020
Chief, Water Enforcement and Compliance Assurance Branch
Water and Wetlands Protection Division
U.S. ENVIRONMENTAL PROTECTION AGENCY, REGION 7
11201 Renner Blvd.
Lenexa, KS 66219
RE: Metropolitan St. Louis Sewer District Consent Decree
Annual Report — Supplement — Calendar Year 2019
Greetings:
The Metropolitan St. Louis Sewer District (MSD) is providing an Annual Report —
Supplement — Calendar Year 2019 in regards to Consent Decree No. 4:07 -CV -1120
(CEJ) entered April 27, 2012. Pursuant to paragraph 33 of the Consent Decree, MSD is
submitting requests for EPA's approval of modifications to the CMOM Program Plan,
which are detailed in the enclosed document.
If you have questions related to this submittal which are not subject to paragraph 129 of
the Consent Decree, please send them to me or by electronic mail at:
CDQuestions@stlmsd.com
Sincerely,
Susan M. Myers
General Counsel
The Metropolitan St. Louis Sewer District
Enclosures: Certification
Report Distribution
Annual Report — Supplement — Calendar Year 2019
Metropolitan St. Louis Sewer District
Annual Report — Supplement — Calendar Year 2019
CERTIFICATION
I certify under penalty of law that this document and all attachments were prepared under
my direction or supervision in accordance with a system designed to assure that qualified
personnel properly gather and evaluate the information submitted. The information
submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am
aware that there are significant penalties for submitting false information, including the
possibility of fine and imprisonment for knowing violations.
DATE: i .I `%Ato o.Z_ID
BRIAN HOELSCHER, P.E.
Executive Director
The Metropolitan St. Louis Sewer District
Metropolitan St. Louis Sewer District
Annual Report — Supplement — Calendar Year 2019
i.1
REPORT DISTRIBUTION
United States:
Chief, Environmental Enforcement Section
Environment and Natural Resources Division
U.S. Department of Justice
Box 7611 Ben Franklin Station
Washington, D.C. 20044-7611
Re: DOJ No. 90-5-1-1-08111
EPA:
Chief, Water Enforcement and Compliance
Assurance Branch
Water and Wetlands Protection Division
U.S. Environmental Protection Agency,
Region 7
11201 Renner Blvd.
Lenexa, KS 66219
David Cozad
Regional Counsel
Office of Regional Counsel
U.S. Environmental Protection Agency,
Region 7
11201 Renner Blvd.
Lenexa, KS 66219
State of Missouri:
Chief Counsel
Agriculture and Environment Division
State of Missouri Office of Attorney General
207 W. High Street
Jefferson City, MO 65102
Chief, Water Pollution Compliance and
Enforcement Section
Missouri Department of Natural Resources
P.O. Box 176
1101 Riverside Dr.
Jefferson City, MO 65101
Director, St. Louis Regional Office
Missouri Department of Natural Resources
7545 South Lindbergh Blvd., Suite 210
St. Louis, MO 63125
Coalition:
Executive Director
Missouri Coalition for the Environment
3115 South Grand Blvd., Suite 650
St. Louis, MO 63118
Maxine I. Lipeles
Elizabeth J. Hubertz
Interdisciplinary Environmental Clinic
Washington University School of Law
One Brookings Drive
Campus Box 1120
St. Louis, MO 63130
MSD:
Executive Director
Metropolitan St. Louis Sewer District
2350 Market Street
St. Louis, MO 63103-2555
General Counsel
Metropolitan St. Louis Sewer District
2350 Market Street
St. Louis, MO 63103-2555
Director of Engineering
Metropolitan St. Louis Sewer District
2350 Market Street
St. Louis, MO 63103-2555
Metropolitan St. Louis Sewer District
ANNUAL REPORT - SUPPLEMENT
- CALENDAR YEAR 2019
December 10, 2020
Metropolitan St. Louis Sewer District
Annual Report – Supplement – Calendar Year 2019
TABLE OF CONTENTS
LIST OF APPENDICES .................................................................................................. 1
ACRONYMS AND ABBREVIATIONS ......................................................................... 2
1.0 INTRODUCTION .................................................................................................. 4
2.0 CMOM PLAN IMPLEMENTATION – PROPOSED CHANGE ..................... 5
2.1 Proposed Change: Sewer Repair, Rehabilitation, or Replacement of
Sewer Pipes ................................................................................................................. 5
2.2 Proposed Change: Pump Station Inspections ........................................ 5
2.3 Proposed Change: Force Main Inspections ............................................ 6
3.0 CONCLUSION ...................................................................................................... 7
Metropolitan St. Louis Sewer District
Annual Report – Supplement – Calendar Year 2019
1
LIST OF APPENDICES
APPENDIX A: MSD REQUEST LETTERS OF SEPTEMBER 21, 2020
Metropolitan St. Louis Sewer District
Annual Report – Supplement – Calendar Year 2019
2
ACRONYMS AND ABBREVIATIONS
Acronym / Definition
Abbreviation
CCTV Closed-Circuit Television
CIPP Cured-In-Place Pipe
CMOM Capacity, Management, Operations and Maintenance
CMP Cityshed Mitigation Program
CSO Combined Sewer Overflow
CY11 Calendar Year 2011
CY12 Calendar Year 2012
CY13 Calendar Year 2013
CY14 Calendar Year 2014
CY15 Calendar Year 2015
CY16 Calendar Year 2016
CY17 Calendar Year 2017
CY18 Calendar Year 2018
CY19 Calendar Year 2019
CY20 Calendar Year 2020
District Metropolitan St. Louis Sewer District
DWS Drinking Water Supply
EPA United States Environmental Protection Agency
FOG Fats, Oils and Grease
FSE Food Service Establishment
HDPE High Density Polyethylene
I/I Inflow and Infiltration
IND Industrial Water Supply
IRR Irrigation
LMRDP Lower and Middle River Des Peres
LTCP Long-Term Control Plan
LWP Livestock and Wildlife Protection
Master Plan Sanitary Sewer Overflow Control Master Plan
MDNR Missouri Department of Natural Resources
Metropolitan St. Louis Sewer District
Annual Report – Supplement – Calendar Year 2019
3
MGD Million Gallons per Day
MSD Metropolitan St. Louis Sewer District
NOV Notice of Violation
ORS Overflow Regulation System
PCMP Post-Construction Monitoring Program
PVC Polyvinylchloride
SCR Secondary Contact Recreation
SEP Supplemental Environmental Project
SSO Sanitary Sewer Overflow
WBC-A Whole Body Contact Recreation-A
WBC-B Whole Body Contact Recreation-B
WQMP Water Quality Monitoring Plan
WWH (HHP) Protection of Warm Water Habitat and Human Health
Protection
Metropolitan St. Louis Sewer District
Annual Report – Supplement – Calendar Year 2019
4
1.0 INTRODUCTION
A Consent Decree between the United States of America, the Missouri Coalition for the
Environment Foundation (“Coalition”), and The Metropolitan St. Louis Sewer District
(“MSD” or “District”) in the matter of The United States, et al. v. The Metropolitan St.
Louis Sewer District, No. 4:07-CV-1120 (E.D. Mo.) has been entered with an Effective
Date of April 27, 2012. Under the Consent Decree, MSD has agreed to make extensive
improvements to its sewer systems to reduce pollution levels in urban rivers and streams.
The objective of the improvement projects is to eliminate or reduce overflows of
untreated raw sewage, priority being given to areas known to be problematic.
Section V. paragraphs 31-33 of the Consent Decree established requirements for MSD to
submit, implement and revise a Capacity, Management, Operations, and Maintenance
Program Plan (“CMOM Plan”). MSD submitted the CMOM Plan on October 27, 2012,
and EPA approved it on January 10, 2013. The Consent Decree and the CMOM Plan
include performance standards for inspecting and maintaining the various components of
MSD’s sanitary and combined sewer systems. Paragraph 33 of the Consent Decree states
“In its Annual Report, MSD shall submit any proposed changes to the Asset Management
Performance Standards (e.g., various mileage requirements), subject to EPA’s
approval…Upon approval of revised Asset Management Performance Standards, said
approved, revised standards shall supersede previously approved standards.”
MSD introduced proposed changes to the CMOM Plan at the September 14, 2020
Consent Decree Status Update Meeting for discussion with EPA staff and stakeholders.
On September 21, 2020, MSD sent EPA two letters proposing revisions to the
performance standards within the CMOM Plan and requesting EPA approval of the
revisions (Appendix A). Then on October 30, 2020, MSD submitted the 2019 Annual
Report.1 After meeting and review of the letters, the 2019 Annual Report, and Consent
Decree paragraph 33, EPA staff requested that MSD propose the modifications in a
supplement to the 2019 Annual Report. In accordance with EPA’s request, MSD is
submitting this Annual Report – Supplement – Calendar Year 2019 (“Supplement”).
This Supplement solely addresses proposed changes to future implementation of MSD’s
CMOM Plan. Any of the proposed changes would occur on and after January 1, 2021.
The Supplement does not revise or modify the material submitted in MSD’s 2019 Annual
Report.
1 The 2019 Annual Report is available on MSD’s website at https://msdprojectclear.org/about/our-
organization/consent-decree/
Metropolitan St. Louis Sewer District
Annual Report – Supplement – Calendar Year 2019
5
2.0 CMOM PLAN IMPLEMENTATION – PROPOSED CHANGE
MSD is proposing to revise CMOM Plan performance standards in three categories:
Repair, Rehabilitation, or Replacement of Sewer Pipes (CD Section V.G.31.d)
Preventative Maintenance Program for Pump Stations (CD Section V.G.31.i)
Inspection and Repair of Force Mains (CD Section V.G.31.k)
2.1 Proposed Change: Sewer Repair, Rehabilitation, or Replacement of
Sewer Pipes
The Consent Decree currently requires MSD to repair, rehabilitate, or replace at least 90
miles of sewer pipe annually for the first ten years after the Effective Date, and thereafter
at least 65 miles annually. Over the original term of the Consent Decree, this equates to a
total of 1,724 miles of sewer. Since the Effective Date, MSD has achieved significantly
more mileage than required on an annual basis, and MSD is forecasting that it will reach
1,724 miles of sewer as early as 2025.
MSD is proposing to modify the CMOM Plan (CD Section V.G.31.d.ii) to utilize current
asset management principles based on asset condition via CCTV review when
determining the mileage of repair, rehabilitation, or replacement of sewer on an annual
basis. MSD proposes implementation of this approach after MSD has repaired,
rehabilitated, or replaced 1,724 miles of its sewer system. MSD will continue to report
the repair, rehabilitated, or replaced mileage in MSD’s Annual Report.
2.2 Proposed Change: Pump Station Inspections
The Consent Decree currently categorizes pump stations for inspection based on
hydraulic capacity. After several years of implementation, MSD concluded this
categorization approach overly complicates the inspection program. Staff believes that
consolidating existing inspection frequencies from three tiers to two will better match
available resources, integrate more closely with other MSD planning processes, and
provide more efficiency in how MSD collects, visualizes, interprets, and acts on data that
result from these inspections.
MSD is proposing to sort pump stations into a risk-based criticality matrix that designates
all pump stations as either “critical” or “non-critical” (CD Section V.G.31.i.ii). MSD will
perform weekly visual inspections of all critical pump stations and monthly visual
inspections of non-critical pump stations. The proposed program is summarized as
follows.
Criticality Inspection
Frequency
Number of
Pump Stations
Critical Weekly 19
Non-Critical Monthly 257
Metropolitan St. Louis Sewer District
Annual Report – Supplement – Calendar Year 2019
6
2.3 Proposed Change: Force Main Inspections
The frequency of visual inspections and non-destructive testing is presently based on the
categorization of the force main as a high-risk, medium-risk, or low-risk asset. MSD is
proposing to consolidate the categorization from three tiers to two, a “critical” category
and a “non-critical” or low-risk category.
All force mains listed in the high-risk (33 total) and medium-risk (31 total) categories
would be moved into the critical category. All critical category force mains would be
visually inspected annually and would undergo non-destructive testing on a once-per-five
year frequency.
No changes in inspections are proposed for the low-risk category of force mains. The 338
existing low-risk force mains would continue to be visually inspected on a once-in-five
year basis.
The proposed program change is summarized in the following table (CD Section
V.G.31.k.ii).
Classification of
Force Main
Frequency
of Visual
Inspection
Frequency of
Non-Destructive
Testing
Inspection
Critical Parts
Inventory and
Emergency
Response
Procedures
Number of
Force Main
Assets in
Category
Critical Annually Once every 5 years Required*64
Non-Critical
(Low-Risk)
Once every 5
years*
N/A* N/A* 338*
*No change proposed, information for clarification only.
All force main assets have had at least one visual inspection, and many assets have had
multiple visual and non-destructive testing inspections. This proposed change will have
no impact on actions already underway to address any system defects or deficiencies
identified during these inspections. However, moving forward, this change will simplify
program management, will standardize the Consent Decree mandated CMOM Plan
requirements with MSD’s Asset Management Program requirements, will be more
efficient and more cost effective from a budgetary and fiscal planning perspective, and
will provide the same level of service with no loss or degradation in-decision making
capability.
Metropolitan St. Louis Sewer District
Annual Report – Supplement – Calendar Year 2019
7
3.0 CONCLUSION
MSD has provided the information contained in this Supplement to comply with
paragraph VIII.73 of the Consent Decree for Case No. 4:07-CV-1120-CEJ. Any
questions regarding the content of this Supplement can be directed to MSD’s Legal
Department. If you have questions related to this report which are not subject to
paragraph XVII.129 of the Consent Decree, please send them by letter or email to:
Susan M. Myers
General Counsel
The Metropolitan St. Louis Sewer District
2350 Market Street
St. Louis, MO 63103
or
Electronic mail at: CDQuestions@stlmsd.com
Metropolitan St. Louis Sewer District
Annual Report – Supplement – Calendar Year 2019
APPENDIX A: MSD REQUEST LETTERS OF SEPTEMBER 21, 2020
SEWER REPAIR, REHABILITATE OR REPLACE – CMOM PLAN
PUMP STATION VISUAL INSPECTIONS, FORCE MAIN VISUAL INSPECTION,
FORCE MAIN NON-DESTRUCTIVE TESTING INSPECTION REVISIONS –
CMOM PLAN
ire
Fl,I
ar
wastewater + stormwater
September 21, 2020
SENT VIA EMAIL
Bruno.Jodi@epa.gov
Ms. Jodi Bruno
Chief, Water Enforcement and Compliance Assurance Branch
Water and Wetlands Protection Division
U.S. Environmental Protection Agency - Region 7
11201 Renner Boulevard
Lenexa, Kansas 66219
RE: The Metropolitan St. Louis Sewer District Consent Decree
Sewer Repair, Rehabilitate or Replace — CMOM Plan
Dear Jodi:
Pursuant to Consent Decree Section V, Subparagraph G.31.d.i.`, "MSD shall permanently repair,
rehabilitate, and/or replace at least $15 million of sewer pipe in the Sewer System annually until the Master
Plan is submitted." MSD has permanently repaired approximately 280 miles of non -PVC sewer pipes
between 2005 and 2010. Pursuant to Section V, Subparagraph G.31.d.ii.2, "MSD shall continue to
permanently repair, rehabilitate, and/or replace at least 90 miles of sewer pipe in the Sewer System annually
for the first ten years after the Effective Date, and thereafter at least 65 miles annually." The Effective Date
of the Consent Decree is April 27, 2012. These asset management performance standards are required to
be included in the EPA approved CMOM Program Plan. MSD's compliance with this requirement is
reported in Section 9.6 and Tables H-9 and H -9a of the Annual Report.
Section V, Subparagraph G.333 of the Consent Decree allows for MSD to submit proposed changes to the
performance standards, subject to EPA's approval. In addition, the CMOM Program Plan, approved on
January 10, 2013, was written to allow flexibility and outlines these principals in Section 2.0 of the CMOM
Program Plan, titled Sewer System Asset Management Process. This section references Section v,
Subparagraph G.33 of the Consent Decree and allows for changes in the performance standards so long as
service levels are met.
In accordance with the CMOM Program Plan, MSD presented information to the EPA during the September
14, 2020 Consent Decree status meeting and made a request to modify the mileage requirements for sewer
repair, rehabilitation, and/or replacement. Under the original terms of the Consent Decree, MSD is required
to repair, rehabilitate, and/or replace 1,724 miles of sewer by 2034, which equates to the cumulative annual
mileage performance standard over the original term of the Consent Decree. Through implementation of
the EPA approved SSO Control Master Plan, in addition to aggressive implementation of the CMOM
program, MSD has achieved significantly more mileage than required on an annual basis. As of the end of
2019, MSD has repaired, rehabilitated, and/or replaced 1,015.6 miles of sewer. Moreover, and prior to the
Effective Date of the Consent Decree, MSD also repaired, rehabilitated, and/or replaced over 402 miles of
sewer. As shown below on the chart, MSD forecasts that it will reach its mileage goal of 1,724 miles by as
early as 2025:
`Page 32 of the Consent Decree.
2 Page 33 of the Consent Decree.
3 Page 37 of the Consent Decree.
MS. JoDl BRUNO
U.S. ENVIRONMENTAL PROTECTION AGENCY
SEPTEMBER 21, 2020
PAGE 2
Annual Miles
500
400
300
200
100
0
Sewer Pipe Repair, Rehab, Replace
N m ct u1 tD h W cr, N m t V1 ID N. CO 01 0 N CO
e-4 .- 4 .-1 .--1 e-1 .--i .--I -1 N N N N N N N N N N m m m m m
O 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
N N N N N N N N N N N N NNNNNN N N N N N
— CD Goal
MOM MSD --111—CD Cumulative
MSD Cumulative CD Term
2500
2000
1500
1000
500
0
-500
-1000
-1500
Cumulative Miles
Through implementation of risk -based asset management processes in the CMOM program for over 8 years,
MSD has found that the asset management needs of the system to meet required service levels do not align
with the current CMOM performance standards for repair, rehabilitation, and/or replacement of a particular
mileage performance standard going forward. Therefore, MSD proposes to modify the CMOM program to
utilize current asset management principles based on asset condition via CCTV review when determining
the mileage of repair, rehabilitation, and/or replacement of sewer on an annual basis. MSD proposes
implementation of this modified approach after MSD has repaired, rehabilitated, or replaced the required
1,724 miles of its Sewer System but will continue to report the repaired, rehabilitated, or replaced mileage
in MSD's Annual Report.
MSD respectfully requests that the EPA review the request to change the mileage requirements for Sewer
System repair, rehabilitation, and/or replacement mileage, and provide your concurrence.
If you have questions, please contact me directly.
Sincerely,
fik
Susan M. Myers
General Counsel
cc: Erin Kleffner (Kleffner.erin@epa.gov)
Liz Huston (Huston.Liz@epa.gov)
Bret Berthold, MSD
Rich Unverferth, MSD
Jay Hoskins, MSD
US*
wastewater + stormwater
September 21, 2020
SENT VIA EMAIL
Bruno.Jodi@epa.gov
Ms. Jodi Bruno
Chief, Water Enforcement and Compliance Assurance Branch
Water and Wetlands Protection Division
U.S. Environmental Protection Agency - Region 7
11201 Renner Boulevard
Lenexa, Kansas 66219
RE: The Metropolitan St. Louis Sewer District Consent Decree
Pump Station Visual Inspections, Force Main Visual Inspections, Force Main
Non Destructive Testing Inspection Revisions — CMOM Plan
Dear Jodi:
Pursuant to Consent Decree Section V, Subparagraphs G.31.i.ii and G.31.k.ii', MSD has
performed Pump Station Visual Inspections, Force Main Visual Inspections, and Force Main Non -
Destructive Testing since MSD entered into the Consent Decree in 2012. The performance
standards established in the above -mentioned subparagraphs went into effect on April 10, 2013 —
90 days after EPA's approval of the CMOM Program Plan. MSD's compliance with this
requirement is reported in Tables H-11, H-12, and H-13 of the Annual Report.
MSD shall continue to perform pump station visual inspections, force main visual inspections, and
force main non-destructive testing on a routine, periodic schedule that continues to conform with
current inspection criteria and parameters, with no substantive proposed changes. Pump station
visual inspections will occur on either weekly or monthly frequencies. Force main visual
inspections will occur on either an annual basis or on an every five (5) year basis. Force main non-
destructive inspections will occur on a per asset basis every five years.
Section V, Subparagraph G.332 of the Consent Decree allows for MSD to submit proposed changes
to the performance standards, subject to EPA's approval. In addition, the CMOM Program Plan,
approved on January 10, 2013, was written to allow flexibility and outlines these principles in
Section 2.0 of the CMOM Program Plan, titled Sewer System Asset Management Process. This
section references Section V, Subparagraph G.33 of the Consent Decree and allows for changes in
the performance standards so long as service levels are met.
1 Pages 34 and 36 of the Consent Decree, respectively.
2 Page 37 of the Consent Decree.
MS. JODI BRUNO SEPTEMBER 21, 2020
U.S. ENVIRONMENTAL PROTECTION AGENCY PAGE 2
In accordance with the CMOM Program Plan, MSD presented information to the EPA during the
September 14, 2020 Consent Decree status meeting and proposed a request to modify the
requirements for pump station and force main inspections.
MSD, as part of its pump station and force main inspection programs, inspects all assets on a cycle
defined in the Consent Decree. The requested modifications presented on September 14, 2020
supported the concept of better aligning the CMOM programs with MSD's overall Asset
Management Program. The larger Asset Management Program has sorted all assets into risk -based,
criticality tiers that define assets as "critical" or "non -critical". The requested program
modifications will align MSD's existing pump stations and force mains into these two (2) risk -
based tiers for the purposes of program management. These modifications will allow MSD to
consolidate existing inspection frequencies into fewer tiers to better match available resources,
integrate more closely with other MSD planning processes, and provide more efficiency in how
MSD collects, visualizes, interprets, and acts on data that results from these inspection processes.
Request No. 1 - Pump Station Inspections. MSD requests that the EPA allow MSD to sort pump
stations into a risk -based, criticality matrix that replaces the current hydraulic capacity
categorization defined in the Consent Decree. If approved, pump stations will be designated as
"critical" or "non -critical" for the purposes of program management and MSD will perform weekly
visual inspections of all critical pump stations and monthly visual inspections of non -critical pump
stations. MSD will also eliminate the bi-monthly inspection entirely and consolidate these
inspections into either the weekly or monthly frequency. See chart(s) below for current and
proposed program summary.
Current Program — Pump Station Inspections
Hydraulic
Capacity
Frequency of Visual
Inspection
Number of
Assets in this
Category
> 5 MGD
Weekly
12 PS
1 — 5 MGD
2x / mo.
16 PS
< 1 MGD
1x / mo.
248 PS
Proposed Program — Pump Station Inspections
Criticality
Frequency of Visual
Inspection
Number of
Assets in this
Category
CRITICAL
Weekly
19 PS
NON -CRITICAL
lx / mo.
257 PS
MS. JODI BRUNO
SEPTEMBER 21, 2020
U.S. ENVIRONMENTAL PROTECTION AGENCY PAGE 3
Request No. 2 — Force Main Inspections. MSD requests that the EPA allow MSD to sort force
mains into a risk -based, criticality matrix that matches what MSD currently utilizes, but
reorganizes force mains into "critical" and "non -critical" asset tiers for the purposes of program
management. If approved, this would replace the high -medium -low risk -based tiers currently
utilized by MSD and high and medium risk force mains would be consolidated into the critical
asset tier. MSD will perform force main visual inspections annually for all critical force mains
and every five (5) years for non -critical force mains. The current medium risk (once every two (2)
years visual inspections) will be consolidated into the critical, annual frequency inspections. See
charts(s) below for existing and proposed program summary.
Current Program — Force Main Inspections
Classification of
Force Main
(Criticality)
Frequency of Visual
Inspection
Number of
Assets in this
Category
HIGH
Annual
33 FM
MEDIUM
1x every 2 year
31 FM
LOW
1x every 5 year
338 FM
Proposed Program — Force Main Inspections
Classification of
Force Main
(Criticality)
Frequency of Visual
Inspection
Number of
Assets in this
Category
CRITICAL
Annual
64 FM
NON -CRITICAL
lx every 5 year
338 FM
Request No. 3 — Force Main Non -Destructive Testing. MSD requests that the EPA allow MSD
to perform force main non-destructive testing inspections every five (5) years for all critical force
mains. If approved, the current medium risk (once every six (6) years) and high risk (once every
three (3) years) inspections would be consolidated into the critical, once every five (5) years
inspections. See charts(s) below for existing and proposed program summary.
Current Program — Force Main Non -Destructive Testing
Classification of
Force Main
(Criticality)
Frequency of Non-
Destructive Inspection
Number of
Assets in this
Category
HIGH
1x every 3 year
33 FM
MEDIUM
1x every 6 year
31 FM
MS. JODI BRUNO
SEPTEMBER 21, 2020
U.S. ENVIRONMENTAL PROTECTION AGENCY PAGE 4
Proposed Program — Force Main Non -Destructive Testing
Classification of
Force Main
(Criticality)
Frequency of Non-
Destructive Inspection
Number of
Assets in this
Category
CRITICAL
lx every 5 years
64 FM
All force main assets have had at least one, and in the case of many assets, multiple visual
inspections and non-destructive testing inspections. These proposed modifications will have zero
impact on actions already underway to address any system defects or deficiencies. These
modifications will also simplify program management, will standardize the Consent Decree
mandated CMOM program requirements with MSD's Asset Management Program requirements,
will be more efficient and cost effective from a budgetary and fiscal planning perspective, and will
provide the same level of service with no loss or degradation in decision making capability.
If approved by the EPA and beginning on January 1, 2021, MSD proposes to change Tables H-11,
H-12, and H-13 performance metrics and will implement the proposed changes to the pump station
and force main inspection programs. These changes will be reflected in the reporting cycle starting
January 1, 2021. MSD respectfully requests that the EPA review the request to revise MSD's
pump station and force main inspection programs and provide your concurrence.
If you have questions, please contact me directly.
Sincerely,
Susan M. Myers
General Counsel
cc: Erin Kleffner (Kleffner.erin@epa.gov)
Liz Huston (Huston.Liz@epa.gov)
Bret Berthold, MSD
Rich Unverferth, MSD
Jay Hoskins, MSD