SEPA
United States December 2014
Environmental Protection
Agency, Region 9
ASSET MANAGEMENT
Incorporating Asset Management Planning
Provisions into NPDES Permits
Overview
Municipalities across the country are facing the challenging obligation to manage their aging
sewer and stormwater systems at a time of urban population growth, more stringent water quality
protection requirements, and increased exposure to climate change-related risks. At the same
time, it has become more difficult for many municipalities to secure new funding for
infrastructure improvements or replacement, or even to
maintain existing funding levels. Asset management
planning is a proven tool for maintaining and elevating
levels of service for wastewater and stormwater
systems and planning system renewal and upgrades.
However, many wastewater and stormwater utilities
have not implemented robust asset management
planning systems or similar infrastructure planning
processes, in part because NPDES permits have rarely
required or encouraged their use.
NPDES permitting authorities should consider
incorporating asset management provisions into their
NPDES permits to ensure permittees implement sound
system operation and maintenance practices, properly
plan for needed system replacements and upgrades, and
meet water quality protection requirements.1
'This document is not a formal U.S. Enviromnental Protection Agency guidance document; nor does it represent
official EPA policy. The Clean Water Act (CWA) and EPA's implementing regulations contain the legally binding
requirements associated with the development of NPDES permits. This document does not substitute for the CWA
or associated permitting regulations. The approaches discussed in this document are not binding; permitting
authorities may consider other approaches consistent with the CWA and associated permitting regulations. This
document is intended to be consistent with, but does not modify existing EPA policy and guidance.
1
Sewer Collection Systems
By the Numbers-
Number of Sanitary Sewer Systems in U.S.
16,000 Systems
Total Length of Public
Sewer Lines
>740,000 Miles
National Wastewater
Infrastructure Need
$192.2 Billion*
National Stormwater Management Need
$22.7 Billion*
*Based on 2008 EPA estimate, j
Page | 1
-------
Introduction
The Clean Water Act ("CWA") National Pollutant Discharge Elimination System ("NPDES")
was established to control water pollution by regulating point sources that discharge pollutants
into waters of the Uni ted States. Publicly Owned Treatment Works ("POTWs") are a significant
source of water pollution and are regulated in a variety of ways under the NPDES program to
ensure discharges from municipalities do not adversely affect receiving waters.
NPDES permits for POTWs include effluent limitations, monitoring and reporting requirements,
best management practices, pretreatment requirements, rules for handling biosolids, and
operation & maintenance requirements.
A POTW's ability to comply with its permit depends on the condition of associated wastewater
collection and treatment infrastructure. A sanitary sewer system in poor shape is vulnerable to
excessive infiltration and other system failures that
may result in:
• Increased flows to POTWs causing pass-through
of pollutants into receiving waters or upset of the
treatment plant.
• Back-ups in the sewer system resulting in Sanitary
Sewers Overflows ("SSOs") of raw sewage onto
streets or into homes or yards.
• Increased costs of pumping and treating addition
water entering the system.
• Costly emergency responses to spills and urgent
reactive reparations.
• Inability to meet new water quality-based permit
requirements.
• Inability to function properly as system
components become more vulnerable to climate change-related impacts (e.g. sea level rise,
flood risk, meteorological changes).
• Additional damage to the collection system resulting in further infiltration.
Complementing sanitary sewer collection systems, Municipal Separate Storm Sewers Systems
("MS4s") transport polluted runoff into local waterbodies during storm and non-storm
conditions. MS4s are also regulated under the NPDES program in order to reduce discharges of
contaminated stormwater runoff through the implementation of stormwater management
Page | 2
Spill type: ^ Category 1 0 Category 2 A Category 3
Click on a map icon for incident information.
Change basemap ¦¦
-'7 <
Las
Vegas
~',SHendi
.(k ^^^akersfiaHK
rfspo& +W
Palm
+orings
IT A
200km
-i-1
100ml
4,840 SSOs resulted in over 9 million
gallons spilled across CA in 2012-13.
-------
programs. While most municipal stormwater systems have different types of conveyance and
treatment infrastructure elements than sanitary sewer systems, stormwater assets are similarly
vulnerable to system failures that cause upsets, flooding, and system damage if they are not
properly maintained and upgraded when necessary. Managing stormwater system assets is
equally critical in order to minimize stormwater pollution, achieve water quality objectives, and
protect communities from flooding.
Background and Benefits
For sewer and stormwater systems, asset management is the process of managing infrastructure
capital assets to minimize total cost of owning and operating them, while delivering an
established and consistent level of service to customers. A high-performing asset management
program incorporates detailed asset inventories, operation and maintenance tasks, and long-range
financial planning to build system capacity, resulting in both environmental benefits and
financial savings. Similar approaches are also used by many drinking water systems.
An infrastructure asset is any long-lived capital asset that is operated as part of a system or
network. Sewers, manholes, and pump stations are the primary asset components of a sewer
collection systems, however buildings integral to the function of the network (e.g., pump station
houses) are also considered assets.
The scope of resources can be additionally expanded
to include hard, natural and soft assets. Hard assets
are physical components and equipment used to
operate a sewer system. Natural assets are
municipally-managed, hydrological resources such as
waterbodies, runoff, and land. Soft assets are social
resources such as personnel, public opinion, policies
and relationships with partners and regulators.
Accounting for resources other than hard assets is a
holistic approach to asset management planning
particularly relevant to stormwater sewer systems.
By incorporating model components into an Asset
Management Plan ("AMP"), a municipality can
reliably forecast needs for maintaining a consistent
level of service and meeting current and future
regulatory requirements. This planning framework
helps municipalities weight difficult investment
decisions, educates the public and political decision makers about system needs, and ensures
proper allocation and acquisition of funding for construction, operation, and maintenance.
Asset management planning can also help maximize energy efficiency of wastewater treatment
and collection operations, yielding further economic benefits.
\
AMP Components
The key elements of an Asset
Management Plan are:
^ Level of service definition.
\
• Selection of performance goals.
• Information system.
• Asset identification and valuation.
• Failure impact evaluation and risk
management.
• Condition assessment.
• Rehabilitation and replacement planning.
• Capacity assessment and assurance.
• Maintenance analysis and planning.
• Financial management.
. • Continuous improvement.
-4
Page | 3
-------
Regulatory Basis
The Federal Code of Regulations requires aNPDES permittee to properly operate and maintain
their facility to ensure compliance with other conditions of the permit. Specifically, all
permittees are required to comply with the following provisions:
40 CFR 122.41(e) Proper operation and maintenance. The permittee shall at all times
properly operate and maintain all facilities and systems of treatment and control (and
related appurtenances) which are installed or used by the permittee to achieve compliance
with the conditions of this permit. Proper operation and maintenance also includes
adequate laboratory controls and appropriate quality assurance procedures. This provision
requires the operation of backup or auxiliary facilities or similar systems which are
installed by a permittee only when the operation is necessary to achieve compliance with
the conditions of the permit.
A NPDES permittee must establish appropriate quality assurance procedures to ensure facilities
meet technology and water quality-based requirements. Quality assurance procedures ensure a
desired level of quality or service. AMPs provide a framework for setting and operating these
quality assurance procedures and ensure permittees have sufficient financial and technical
resources to continually maintain a targeted level of service. At the discretion of a permitting
authority, AMP requirements may be established to ensure compliance with the provisions of 40
CFR 122.41(e). Moreover, AMP provisions may be incorporated as part of compliance actions to
ensure permittees take proper steps to repair and maintain failed infrastructure to address permit
violations and prevent their recurrence.
Permit Language for Sanitary Sewer Systems
This section provides permit recommendations and sample language for use in incorporating
AMP provisions in permits. In order to incorporate AMP language into NPDES permits,
permitting authorities need to address the key elements of an AMP plan identified in the box on
page 3. The level of detail established in the permit requirements may vary based on the size of
the collection system.
This report provides an example framework to establish conditions that will provide an impetus
for municipalities to engage in AMP targeting, assessing, planning and forecasting. Requiring
permittees to utilize AMPs is not only legally defensible, but will minimize environmental
damage while saving money for municipalities for years to come.
Asset management planning language can be simplified into four permit sections: Targeting,
Assessment, Planning, and Forecasting.
Page | 4
-------
Targeting
Targeting requires a permittee to delineate the
purpose and goals of their AMP and includes a
level of service definition and selection of
performance goals. Written as an NPDES permit
requirement, the definition of level of service
must identify, but is not limited to, a level of
service necessary to maintain NPDES
compliance. For wastewater treatment plants, the
level of service should include reducing SSOs and
peak flows to the facility and meeting other
permit conditions, such as effluent limitations.
Performance goals are specific metrics to assess
how the defined levels of service are being met.
Such goals could include inspection frequencies,
peak flow volumes, FOG build-up, or water-quality concentrations.
Levels of service and performance goals may also be established on the individual asset level to
set qualitative and quantitative expectations for specific pieces of equipment.
Assessment
Assessing a system requires not only
inventorying all assets, but also assessing
possible failure paths and potential impacts if
system components fail.
To assess the system, the permittee must first
select an appropriate information system,
enabling them to adequately collect and maintain
the information necessary to implement an
AMP. Once an information system has been
selected, the permittee may initiate asset
identification and valuation, a process of
identifying and numbering the primary
components in the sewer system. Asset data such
as location (i.e., GPS coordinate or equivalent
identifier), size, age, cost, and desired level of
service (quantitative expected performance) are
all examples of the essential information to be
compiled. Asset data inventories provide very
useful maps of the locations and
interrelationships among individual system components along with meta data about the histories
and replacement/inspection schedules for individual components.
Assessment
Example Language
/ \
The permittee shall identify and inventory
all critical wastewater assets valued over
$5,000 into a single database. Each entry
shall include:
a) Name and identification number.
b) Location (GPS coordinate or
equivalent identifier)
c) Desired level of service (quantitative
expected performance).
d) Current performance.
e) Purchase and installation date.
f) Purchase price.
g) Replacement cost.
h) Consequence of failure.
i) Likelihood of failure.
Page | 5
-------
Once inventoried, the permittee may carry out failure impact evaluation and risk management
assessments. This process is designed to project the likelihood and consequences of failure
should the asset no longer operate. Factors to consider in evaluating consequences of failure may
include location, function, depth, or proximity to public areas or environmental resources.
The last phase of assessment is the condition assessment, performed to identify assets that are
underperforming, determine the reason for the deficiencies, predict when failure is likely to
occur, and determine what corrective action is needed and when. During this phase,
municipalities evaluate the condition of each asset and assign an appropriate numeric grade
based on an established scale.
Comparing consequences of failure with likelihoods of failure is the basis of asset management
planning and ultimately allows a municipality a quantitative mechanism for prioritizing asset
reparation and replacement.
Planning
Once assets are fully inventoried and assessed, the permittee will use the information to make
more informed decisions on how to improve their system to meet a desired level of service and
plan for future needs and requirements.
Proactive rehabilitation and replacement planning provides the best opportunity for capital cost
savings and environmental protection. By balancing factors such as condition of the asset,
consequence of asset failure, and cost of replacement,
a municipality can systematically prioritize the
rehabilitation and replacement of assets.
Capacity assurance planning is commonly addressed
as a standard condition in most NPDES permits,
however it can be required by the permit as a
component of a permittee's asset management
planning effort. A robust capacity assurance plan
compares peak flow data with operational difficulties
and SSO occurrences, and then identifies how
regional growth patterns and new permit requirements
might affect such system shortfalls. The capacity
assurance effort can be incorporated into the asset
management planning effort to prioritize
replacements and upgrades.
Effective maintenance analysis and planning
programs keep sewer systems running smoothly and
help prevent premature deterioration. The goal of the p
maintenance activities while minimizing unplanned, or "reactive," maintenance activities. By
conducting strategic maintenance to analyze past failures, municipalities can anticipate and
prevent future failures.
Planning
Example Language
As part of the Asset Management
Plan, the permittee shall create and
implement a Maintenance,
Rehabilitation, and Replacement Plan.
The MRRP shall evaluate data
obtained through asset assessment in
order to inform a strategy for
prioritizing and scheduling
maintenance of the sewer system and
rehabilitation and replacement of
inventoried assets. The MRRP shall be
re-assessed annually to address
» changing conditions and resources.
)lanning process is to maximize planned
Page | 6
-------
Forecasting
Information collected through the assessment
phase of asset managing planning is not used only
to inform infrastructure maintenance and
replacement priorities, but also to forecast the
funding needed to meet levels of service goals.
With proper financial management, a
municipality may identify funding it will need
and when it will need it in order to establish a
basis for planning user fees, debt financing, and
other funding solutions.
The last component of an effective AMP is
acknowledgment of its iterative nature and the
need to regularly update the AMP. A municipality
must focus on continuous improvement by
periodically reviewing their system against
performance measures to identify any shortfall in
their AMP. If the permittee is unsuccessful in meeting performance measures despite
implementing the components of their AMP, then the strategy must be adjusted to better achieve
their desired outcomes.
Stormwater Systems
Although asset management planning is a popular tool in maintaining levels of service for water
and wastewater systems, stormwater system managers are only beginning to explore its use.
While stormwater system assets are very different than sanitary sewer system assets, the AMP
principles are consistent across water systems.
Compared to wastewater management, stormwater less frequently receives direct treatment to
remove pollutants discharged through stormwater outfalls, thereby making it more challenging to
meet numeric effluent limitations. However, a stormwater system's obligation to meet
limitations, particularly those introduced through Total Maximum Daily Loads ("TMDLs"), is
no less important than it is for discharges from more conventional point sources. For stormwater
systems, asset management planning becomes increasingly essential as a means of leveraging
assets to meet performance measures, such as TMDL or other water quality based pollutant
reduction requirements or goals. An AMP system can also provide a basis to identify funding
needs, set priorities among competing control demands, and demonstrate how resources will be
dedicated to achieve specific results.
Forecasting
Example Language
The permittee shall project costs
necessary to meet each desired level of
service. The permittee shall then compare
these projections with available funding
sources to determine the best manner in
which to fund operation and maintenance,
repair, rehabilitation, and replacement of
assets to sustain service and performance.
The permittee shall re-evaluate its asset
management plan on an annual basis and
make the plan available to the permitting
yauthority upon request. ,
Page | 7
-------
Permit language for MS4 permits can be developed
on a permit-specific basis and account for natural,
and potentially soft assets, in addition to
conventional hard assets more prevalent in a sanitary
sewer system. Stormwater permits may also include
asset management targeting, planning, forecasting,
and implementation language similar to the examples
provided above.
Permittees may also be able to use this opportunity to
demonstrate compliance with effluent limitations
through the implementation of their AMP. By setting
a target level of service, such as meeting TMDL-
based numeric effluent limitations, a permittee may
model what best management practices are necessary
to meet that goal and how much it will cost to build and maintain them over the course of time
required to attain their desired water quality. Permitting authorities may then decide to allow for
attainment of effluent limitations through the implementation of an AMP.
Sustainability
The deterioration of aging infrastructure, population growth, and asset failure patterns are all
factors that should be incorporated into an effective AMP. An AMP can also be used to forecast
relevant needs and costs associated with climate change-related impacts, particularly in
communities that will be impacted by sea level rise or increased flooding risk. By outlining how
changing weather patterns and natural disasters might affect municipal wastewater and
stormwater systems, municipalities can develop long-
term construction and funding plans for upgrading or
relocating critical infrastructure.
Asset management planning for climate change
requires a dynamic understanding of the effects of
climate change on local communities. Permittees must
model what effects extreme weather events, sea level
rise, shifting precipitation and runoff patterns,
temperature changes, and resulting changes in water
quality and availability will have on their sewer
systems before being able to identify adaptation
strategies and secure funding for implementation.
Permitting authorities may consider including climate
change requirements into an NPDES permit after a municipality has already demonstrated an
ability to implement an effective AMP. USEPA's Climate Ready Water Utilities Program has
Page | 8
-------
resources to help wastewater utilities prepare for a changing climate at
http://water.epa.gov/infrastructure/watersecuritv/climate.
Aside from accounting for impact resulting from climate change, sewer systems have an
obligation to optimize their energy efficiency. Drinking water and wastewater systems account
for approximately 3-4 percent of energy use in the United States. Using asset management
planning to maximize the energy efficiency of wastewater treatment and collection operations
can yield substantial economic benefits, in addition to helping cut down on associated emissions.
Many state and federal programs are available to fund energy efficiency projects, and
improvements are often eligible for rebates from energy utilities to reduce the payback periods
even further. USEPA Region 9's Sustainable Water Infrastructure website
(http://www.epa.gov/region9/waterinfrastructure/index.htmn describes a recommended approach
for implementing an energy efficiency program at wastewater utilities.
Permitting authorities may additionally consider mandating energy efficiency audits as part of
the asset management planning process in NPDES permits.
Implementation
Asset management planning is currently underway across the country. EPA Region 9 is putting
together a series of case studies to showcase the status of asset management planning for various
wastewater and stormwater systems in the U.S., with a focus on California. The case studies will
be available on EPA Region 9's website.
As AMP efforts gain momentum, appropriate
NPDES permit requirements are beginning to be
developed for permits in EPA Regions 1 and 5 in
the Northeast and Midwest. Specifically, most
permits issued in Region 1 and Wisconsin include
provisions for incorporating EPA's Capacity,
Management, Operations and Maintenance
program, while permits issued by Region 5 and in
Michigan require inventorying, level of service
planning, critical asset identification, life cycle
costing, and long-term funding strategizing.
Depending on the structure of permits, asset
management requirements may be incorporated as
a "special condition," if applied on a facility-
specific basis, or even a "standard condition," when
applied genetically across all permits. Language may also be incorporated into a distinct
"operation & maintenance" or "asset management planning" section.
Case Studies
Cities of Folsom and Son Diego
Folsom
By developing a Rehabilitation and
Replacement Program, Folsom has secured
$33 million over 16 years for R&R projects.
Since 1998, the City has reduced sewer spill
events by 80%.
San Diego
The City's Watershed Asset Management
Plan identified a nearly $20 billion need
over the next 100 years to meet level of
^ervice goals, including TMDL compliance, j
Page | 9
-------
As sewers age, cities grow, and the climate changes, the need for increasingly sophisticated
infrastructure management will become more prevalent. By incorporating asset management
planning as a requirement into NPDES permits, we are taking one step closer to achieving the
Clean Water Act goal of eliminating all sources of pollutant discharge.
Reference Materials
Fact Sheet: Asset Management for Sewer Collection Systems. U.S. EPA. Apr 2002.
http://water.epa.gov/polwaste/npdes/sso/upload/assetmanagement.pdf
Asset Management Language; A Guide; Draft. Michigan Department of Environmental Quality.
Dec 2012.
Clean Watersheds Needs Survey 2008 Report to Congress. U.S. EPA. EPA-832R-10-002.
http://water.epa.gov/scitech/datait/databases/cwns/upload/cwns2008rtc.pdf
Energy Efficiency in Water and Wastewater Facilities. U.S. EPA. 2013, EPA-430-R-09-038.
http://epa.gov/statelocalclimate/documents/pdf/wastewater-guide.pdf
Publication Information
U.S. Environmental Protection Agency, Region 9
Water Division
75 Hawthorne Street
San Francisco, CA 94105
Jamie Marincola
Marincola.JamesPaul@epa.gov
415-972-3520
Page | 10
------- |