2023-16 Ordinance Amending City Code Chapter 74 - Sanitary Sewer System

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APPENDIX A Ellen and Division Inflow and Infiltration Reduction Program Administrative Consent Order In 2012, the United States Environmental Protection Agency(US EPA) served Decatur with an Administrative Consent Order(ACO), requiring the City to eliminate wet weather overflows and reduce wet weather basement backups. Staff retained outside legal counsel with expertise and direct experience in US EPA administration of the Clean Water Act. With the assistance of outside counsel and AECOM, extensive negotiations between the City and the US EPA resulted in the US EPA's issuance of an ACO that was greatly limited in scope compared to the initial Order. This was in large measure due to the City's ongoing commitment to improving its sanitary sewer systems, and its good faith efforts to negotiate a reasonable ACO with the US EPA. The Administrative Consent Order's major requirements included: 1. A Development of a Capacity Management, Operations, and Maintenance (CMOM) program. The CMOM program provides a comprehensive review of the City's sewer collection system asset, including system management, maintenance, and capital improvement funding. The CMOM was approved by the USEPA on May 1, 2018 and the City has implemented the program. 2. Preparation of a Sewer Collection System Alternatives Analysis (SCSAA) for areas identified as experiencing Sanitary Sewer Overflows (SSOs) and sewer back-ups during storm events. The analysis focused on efforts to keep storm water from entering into the separate sanitary sewer system and better manage stormwater entering the combined sewer system. US EPA Administrative Consent Order Status The City submitted a third revision to the required Sanitary Sewer Collection System Analysis (SCSAA) on November 30, 2017. The revised SCSAA identified four major areas of concern: (see attached SCSAA Target Areas Location Map) 1. North Lost Bridge Area 2. Florian Avenue Area 3. Basin 5/6 Area(Grand/Rt.48) 4. Ellen/Division Area The Ellen/Division Area was identified as an additional study area during the rainfall events that occurred during the preparation of the revised SCSAA. Rainwater induced sanitary sewer overflows persisted in the area despite increased sewer system maintenance. These persistent overflows required that an Inflow and Infiltration(I&I) study be completed, and the system be added to the list of priority areas to be addressed by the City as identified in the SCSAA.