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APPENDIX A <br /> GENERAL BACKGROUND: <br /> Administrative Consent Order <br /> In 2012,the United States Environmental Protection Agency(US EPA)served Decatur with an <br /> Administrative Consent Order(ACO),requiring the City to eliminate overflows and reduce <br /> basement backups. Staff retained outside legal counsel with expertise and direct experience in <br /> US EPA administration of the Clean Water Act. With the assistance of outside counsel and <br /> AECOM,extensive negotiations between the City and the US EPA resulted in the US EPA's <br /> issuance of an ACO that was greatly limited in scope compared to the initial Order. This was in <br /> large measure due to the City's ongoing commitment to improving its sanitary sewer systems, <br /> and its good faith efforts to negotiate a reasonable ACO with the US EPA. <br /> The Administrative Consent Order's major requirements include: <br /> 1. The development of a Capacity Management,Operations,and Maintenance(CMOM) <br /> program. The CMOM program provides a comprehensive review of the City's sewer <br /> collection system,including system management,maintenance,and capital improvement <br /> funding. The City's CMOM program was approved by the USEPA on May 1,2018 and <br /> has been implemented as required by the ACO. <br /> 2. The preparation of a Sewer Collection System Alternatives Analysis(SCSAA)for areas <br /> identified to be experiencing Sanitary Sewer Overflows(SSOs)and sewer back-ups <br /> during storm events. This analysis is focused on keeping storm water from entering into <br /> the separate sanitary sewer system and to better manage stormwater entering the <br /> combined sewer system. <br /> US EPA Administrative Consent Order Status <br /> The current version of the City's Sanitary Sewer Collection System Analysis(SCSAA)identified <br /> four top priority areas of the City experiencing high inflow and infiltration during storm events. <br /> It should be noted that these are not the only areas in the City with high rain induced sewer <br /> problems but these are the highest priority areas. <br /> 1. North Lost Bridge Area <br /> 2. Florian Avenue Area <br /> 3. Grand and Oakland Area(Basin 5&6 in the SCSAA) <br /> 4. Ellen/Division Area <br /> The Oakland and Grand area was identified in the SCSAA due to its history of wet weather <br /> basement backups. The predominant cause of basement backups in the area is the combined <br /> sanitary sewers where both sanitary sewage and storm water are carried in the same pipe. <br /> Combined sewers serve nearly 40%of the City,mostly in the older areas. <br /> The City has not received any correspondence regarding the SCSAA from the USEPA since the <br /> current version was submitted on November 30,2017. The plan has still not received final <br /> approval;however,following discussions with the City Council in the fall of 2020,it was <br /> determined to move forward in addressing the known sewer problems. <br /> Page 14 <br />