Semi-Annual Report of Consent Decree Implementation · 2019. 4. 25. · Summary of Partial Consent...

Semi-Annual Report ofConsent Decree Implementation

September 30, 2015

Prepared By:

Reporting Period: January 1, 2015 to June 30, 2015

http://capitalregionwater.com/

i

Table of Contents

Section 1 Introduction ..................................................................................................... 1-1

1.1 Partial Consent Decree ........................................................................................................................................... 1-1

1.2 Semi-Annual Report Requirements .................................................................................................................. 1-1

1.3 Reporting Period ....................................................................................................................................................... 1-1

Section 2 Summary of Partial Consent Decree Deadlines .................................................. 2-1

2.1 Reporting Requirements ....................................................................................................................................... 2-1

2.2 Partial Consent Decree Deadlines...................................................................................................................... 2-1

Section 3 Summary of Progress to Date and Upcoming Tasks ........................................... 3-1

3.1 Overview of Progress and Projected Work ................................................................................................... 3-1

3.1.1 Reporting Requirements.......................................................................................................................... 3-1

3.1.2 Compliance Table ........................................................................................................................................ 3-1

3.1.3 Legal Authority and Rules and Regulations ................................................................................... 3-17

3.1.4 NMC Plan and OMM Development ..................................................................................................... 3-17

3.1.5 Conveyance and Collection System Inspection and Mapping ................................................ 3-18

3.1.6 Conveyance and Collection System Rehabilitation Planning ................................................. 3-19

3.1.6.1 Reporting Requirements .......................................................................................................... 3-19

3.1.6.2 Progress Update ........................................................................................................................... 3-19

3.1.7 Cityworks Data Management System ............................................................................................... 3-19

3.1.8 Public Notification .................................................................................................................................... 3-19

3.1.8.1 Reporting Requirements .......................................................................................................... 3-19

3.1.8.2 Progress Update ........................................................................................................................... 3-19

3.1.9 CAMP Study ................................................................................................................................................. 3-19

3.1.10 MS4 Permitting and Planning ........................................................................................................... 3-20

3.1.11 IFMMPP ...................................................................................................................................................... 3-20

3.1.11.1 Reporting Requirements ....................................................................................................... 3-20

3.1.11.2 Progress Update ........................................................................................................................ 3-20

3.1.12 LTCP Development ................................................................................................................................ 3-20

3.1.13 AWTF Construction Project ............................................................................................................... 3-21

3.1.14 Discussion of Issues/Noncompliance ............................................................................................ 3-21

3.1.14.1 Reporting Requirements ....................................................................................................... 3-21

3.1.14.2 Progress Update ........................................................................................................................ 3-22

3.2 Wet Weather Program Management Schedule .......................................................................................... 3-22

3.2.1 Reporting Requirements........................................................................................................................ 3-22

3.2.2 Progress Update ........................................................................................................................................ 3-22

Section 4 Summary of Events and Discharges ................................................................... 4-1

4.1 Correspondence with Plaintiffs .......................................................................................................................... 4-1

4.1.1 Reporting Requirements.......................................................................................................................... 4-1

4.1.2 Summary of Correspondence ................................................................................................................ 4-1

4.2 NPDES Permit Exceedances ................................................................................................................................. 4-1

Table of Contents

ii

4.2.1 Reporting Requirements .......................................................................................................................... 4-1

4.2.2 Summary of Exceedances ........................................................................................................................ 4-1

4.3 Sanitary Sewer Overflows and Unauthorized Discharges ....................................................................... 4-1


4.3.2 Summary of SSOs and Unauthorized Discharges ........................................................................... 4-2

4.4 Combined Sewer Overflows (and DWOs) ....................................................................................................... 4-3


4.4.2 Summary of CSOs and DWOs.................................................................................................................. 4-3

4.5 AWTF Secondary Bypasses ................................................................................................................................... 4-4


4.5.2 Summary of Bypasses ................................................................................................................................ 4-4

No table of contents entries found.

List of Tables

Table 2.1 CRW Partial CD Deliverable Schedule and Tracking ........................................................................... 2-1

Table 3.1: General Description of Work Completed in Reporting Period and Planned for Next

Reporting Period .................................................................................................................................................................... 3-3

Table 4.1: Summary of Sanitary Sewer Overflows and Unauthorized Discharges (UD) ......................... 4-2

Table 4.2: Summary of AWTF Secondary Bypasses ................................................................................................ 4-5

Appendices

Appendix A NMC Plan Summary Table

Appendix B CSO Report

1-1

Section 1

Introduction

1.1 Partial Consent Decree Capital Region Water entered into a partial Consent Decree (CD) with the Department of Justice

(DOJ), United States Environmental Protection Agency (EPA), and the Pennsylvania Department

of Environmental Protection (DEP) for the management of their combined, sanitary, and

stormwater sewer systems, as well as their pumping stations and Advanced Wastewater

Treatment Facility. The Date of Lodging for the partial CD was February 10, 2015. This date

serves as the starting point for multiple deadlines within the partial CD, whereas other dates

were independently established and in some cases precede the Date of Lodging. The partial CD

became effective when it was entered by the Court on August 24, 2015.

1.2 Semi-Annual Report Requirements This Semi-Annual Report fulfills the requirements of the partial CD outlined in the following

sections:

�� Section VII.A.43

�� Appendix A

The relevant partial CD requirements for each subsequent section of this report are highlighted

preceding each narrative.

1.3 Reporting Period This report is the first Semi-Annual Report, since the Date of Lodging falls within this reporting

period of January 1, 2015 to June 30, 2015. However, since there were certain partial CD

requirements that preceded January 1, 2015, as well as several key tasks that were initiated in

advance of the Date of Lodging, this report will also summarize CRW’s progress prior to January

1, 2015 as well.

Section 1 • Introduction

1-2

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2-1

Section 2

Summary of Partial Consent Decree Deadlines

2.1 Reporting Requirements The partial consent decree outlines the following requirements:

�� VII.A.43.a & Appendix A.a: A statement setting forth the deadlines and other terms that CRW

was required by this Consent Decree to meet since the date of the last Semi-Annual Report,

whether and to what extent CRW met these requirements, the reasons for any noncompliance,

and steps that are being taken to get back on schedule.

2.2 Partial Consent Decree Deadlines CRW has fulfilled the requirements during this reporting period from January 1, 2015 to June 30,

2015, as summarized in Table 2.1. The related tasks are highlighted in green within the table.

Additionally, CRW completed the activities with completion deadlines prior to January 1, 2015,

which are also summarized in Table 2.1. The related tasks are highlighted in gray within the table.

Although the partial CD does not specifically define the quarterly report deadlines for the AWTF

Construction project and the IFMMPP, those reports were submitted on the dates outlined in

Table 2.1.

Table 2.1 also identifies future compliance deadlines stipulated by the partial CD. In some cases,

as of the date of this report additional deliverables have been submitted and the related dates are

included for a comprehensive assessment of CRW’s progress. These dates are highlighted in blue

in Table 2.1. Upcoming deadlines that will be included in the next Semi-Annual Report that have

not been completed as of the date of this report are highlighted in yellow within Table 2.1.

Table 2.1 CRW Partial CD Deliverable Schedule and Tracking

Deadline Deliverable Section No. Submission / Completion

Date

Initial Flow Metering and Monitoring Program Plan (IFMMPP) V(E)(15) 7/1/2013

IFMMPP Quarterly Reports V(E) (15)(f) 1/29/15, 4/24/15, 7/29/15

2/15/14 AWTF Upgrade Notice to Proceed V(H)(32)(b)(i) 3/14/14

AWTF Upgrade Quarterly Reports V(H)(32)(b)(ii) Monthly Reports

10/1/14 MS4 Individual Permit Application V(D)(13) 10/1/14

10/31/14 Interceptor Structural Assessment V(G)(31)(a) 10/31/14

11/28/14 Nutrient Credit Purchase V(H)(32)(c) 11/3/14

12/30/14 Define Approach for LTCP Alternative Evaluation V(E)(16) 12/23/14

12/31/14 Interim Resolution with City on Legal Authority Agreements V(B)(10) 10/1/14

2/10/15 Date of Lodging of Consent Decree IV(8)(p) 2/10/15

Section 2 • Summary of Partial Consent Decree Deadlines

2-2

Deadline Deliverable Section No. Submission / Completion

Date

3/1/15 Interceptor Construction Schedule V(G)(31)(a) 2/25/15

5/10/15* CSO Activation Monitoring Pilot (CAMP) Study Plan V(G)(31)(d) 5/8/15

8/1/15 Water Quality Modeling Plan (Demonstration Approach Only) V(E)(16) 7/29/15

8/1/15 Long-Term Rainfall / Typical Year TM V(E)(20) 7/29/15

8/10/15* Nine Minimum Controls (NMC) Plan / O&M Manual V(C)(11) 8/10/15

9/30/15 Semi-Annual Report / Meeting VII(A)(43) 9/30/15

12/31/15 Upgrade Satellite Community Flow Meters V(E)(15)(c) 8/21/14

2/10/16 CSO Outfall Structure Repair and Schedule V(G)(31)(c)

2/10/16* Capacity Assessment Plan V(F)(30)(a)

2/15/16 AWTF Upgrade Construction Complete V(H)(32)(b)(iii)

3/31/16 Semi-Annual Report / Meeting (with Chapter 94 Report) VII(A)(43)

4/1/16 Sewer System H/H Model Report V(E)(15)(h)

4/1/16 Sensitive Areas / Priority Areas TM V(E)(19)

4/1/16 Financial Capability Analysis V(E)(18)

8/10/16* Annual Update of NMC Plan / O&M Manual V(C)(11)(a) & V(C)(12)

9/30/16 Semi-Annual Report / Meeting VII(A)(43)

12/1/16 CAMP Study Report V(G)(31)(d)


4/1/17 Existing System Characterization V(E)(21)

4/1/17 Capacity Assessment Report with repair schedule V(F)(30)(c)



12/31/17 Paxton Creek Interceptor Priority Remedial Work V(G)(31)(a)

2/10/18* Sinkhole Remediation V(G)(31)(b)


4/1/18 Long Term Control Plan V(E)(14)



12/31/18 Asylum Run & Front Street Ph. I Interceptor Priority Remedial Work V(G)(31)(a)

3/31/19 Semi-Annual Report (with Chapter 94 Report) VII(A)(43)





12/31/20 Front Street Interceptor Priority Remedial Work V(G)(31)(a)

* Based on Date of Lodging of Consent Decree of February 10, 2015.

3-1

Section 3

Summary of Progress to Date and Upcoming Tasks

3.1 Overview of Progress and Projected Work

3.1.1 Reporting Requirements

The partial consent decree outlines the following requirements:

�� Appendix A.b: A general description of the work completed within the Six-month Period, and a

projection of work to be performed pursuant to this Consent Decree during the next or

succeeding Six-month Period. This description of work completed should include Nine

Minimum Controls and Minimum Control Measures activity during the past Six-month Period.

Notification to U.S. EPA and PADEP of any anticipated delay shall not, by itself, excuse the

delay;

�� VII.A.43.b: A description of the projects, work, and activities completed during the prior six-

month period, and a projection of the projects, work, and activities to be performed pursuant

to this Consent Decree during the next or succeeding six-month period;

3.1.2 Compliance Table

In order to document the relationship between the work that CRW has completed and each line

item within the partial CD, Table 3.1 outlines the following items:

�� Partial CD Reference

�� Description of Partial CD Requirement

�� Deadline

�� Progress to Date (through 6/30/15)

�� Proposed Work (through 12/31/15)

�� Compliance Status

CRW has completed all of the requirements of the partial CD that have deadlines prior to June 30,

2015. Additionally, CRW has made significant progress in developing programs and projects in

order to fulfill the future requirements of the partial CD. As of the date of this report, CRW has

already fulfilled the partial CD deadlines that fall within the July 1, 2015 to December 31, 2015

reporting period.

Section 3 • Summary of Progress to Date and Upcoming Tasks

3-2

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Consent Decree

Paragraph Progress to Date (through 6/30/15) Proposed Work (through 12/31/15)

Compliance

Status

Table 3.1: General Description of Work Completed in Reporting Period and Planned for Next Reporting Period

Consent Decree Requirement

Deadline in Consent

Decree / Submittal

V.B LEGAL AUTHORITY

V.B.10Secure legal authority for enforcement, operation, and

maintenance of sewer system and MS4, including:

V.B.10.a inspect and regulate grease traps

V.B.10.b inspect and regulate non-domestic users

V.B.10.cimplement MS4 permit and MCMs, including illicit discharge

elimination and post construction storm water management

V.B.10.d maintain and repair connections to the sewer system and MS4

V.B.10

Negotiate an interim resolution with the City with a schedule

for the implementation of rules, regulations, ordinances, and

other legal mechanisms. NMC Plan and MS4 Permit

Application shall include similar schedules.

CD 2/10/2015

CRW entered into an "Intergovernmental Cooperation

Agreement" with the City of Harrisburg to facilitate and assist in

environmental compliance on 10/20/14. CRW continued advance

their revised Rules and Regulations. The MS4 permit established a

schedule of to implement new rules and regulations one year

from the start of the permit term. The NMC Plan defined a

deadline of 8/10/16 for the revised rules and regulations.

CRW will continue to update the revised Rules and

Regulations. Complete

V.C NINE MINIMUM CONTROLS

V.C.11

Prepare an NMC Plan that evaluates and documents current

NMC implementation and provides a schedule of actions to

achieve compliance with the CSO Policy.

CD 8/10/2015

CRW prepared and submitted the NMC Plan to the regulatory

agencies on 8/10/15. The NMC Plan provides a detailed account

of the current practices for NMC compliance and outlines

proposed programs with schedules to achieve NMC compliance in

the future.

CRW will continue to review the NMC Plan and make

note of recommended modifications for the annual

update.

Complete,

Updates

Ongoing

V.C.11.a

Conduct proper operation and regular maintenance of the

conveyance and collection systems. Develop an operation

and maintenance program. Prepare, update, and maintain an

Operation & Maintenance Manual, which shall include:

CD 8/10/2015

In parallel with the preparation of the NMC Plan, CRW prepared

an OMM that was submitted to the regulatory agencies on

8/10/15.

CRW will continue to review the OMM and make


update.

Complete,

Updates

Ongoing

V.C.11.a.i A list of critical facilities and equipment.NMC

Plan 4/1/2016

CRW's OMM Section 3 provides information on the critical

facilities and equipment within the conveyance system and at the

AWTF; however at this time the critical facilities in the collection

system are not yet defined.

CRW will continue to review and update the list of

critical equipment and facilities, specifically once the

collection system manhole inspections are complete

in Fall 2015 CRW can identify critical facilities in the

collection system.

Complete,

Updates

Ongoing

NMC

Plan8/10/2016

CRW entered into an "Intergovernmental Cooperation

Agreement" with the City of Harrisburg to facilitate and assist in

environmental compliance on 10/20/14. CRW continued advance

their revised Rules and Regulations.

CRW will continue to update the revised Rules and

Regulations.

No Delay

Anticipated

3-3

Consent Decree


Compliance

Status



Deadline in Consent

Decree / Submittal

V.C.11.a.iiA program to divide the conveyance and collection systems

into different sewersheds and catchments.

NMC

Plan4/1/2016

CRW continued to develop the GIS mapping of their combined

sewer, sanitary sewer, and separate storm sewer systems

through (1) the acquisition and review of record drawings and

maps, (2) MS4 field investigations, (3) aerial survey of all surface

structures, and (4) hiring a contractor to perform manhole

inspections within the entire collection system. As the GIS

mapping was developed it was utilized to update the sewershed

delineations.

The collection system manhole investigation will be

completed by 12/31/15, and in the future this will be

utilized to refine the sewershed and catchment

delineations.

Ongoing, No

Delays

Anticipated

V.C.11.a.iii

A program to locate, characterize, and map the diameter,

length, elevation, construction material, and installation date

of the collection and conveyance systems.

NMC

Plan4/1/2016

CRW continued to develop the GIS database of their combined



maps, (2) conducting an inspection of all the interceptors (both

separate and combined), (3) entering into a contract for

inspection of all collection system manholes, and (4) conducting a

field investigation of MS4 inlets and manholes.


completed by 12/31/15, and in the future this

information will be utilized to update the GIS

database.

Ongoing, No

Delays

Anticipated

V.C.11.a.iv

A program to evaluate the structural integrity and

maintenance needs of the conveyance and collection systems

through internal inspections and visual inspections at sinkholes

and the ground surface with highest priority on critical areas.

NMC

Plan4/1/2016

CRW conducted an internal inspection of all the interceptors

(combined and separate) in 2014, which involved inspecting

71,000 linear feet sewer ranging from 24" to 72" diameter witha

combination of CCTV, sonar, and laser profiling. CRW entered into

a contract with Hydrostructures to conduct inspections of each

manhole within the collection system June 2015. CRW entered

into a contract with U.S. Army Corps of Engineers to conduct

inspections of the MS4 system, which is now approximately 30%

complete.


completed by 12/31/15.

Ongoing, No

Delays

Anticipated

V.C.11.a.v

A program to inventory and inspect all force mains:

documenting material, age, installation date, diameter,

length, corrosion protection, and flow rates and develop a

schedule for periodic evaluation

NMC

Plan6/30/2016

CRW has reviewed and selected applicable technologies for the

force main inspection, which were summarized in a technical

memo dated March 24, 2015. CRW coordinated with vendors

regarding the inspection.

CRW plans to conduct the force main assessment

during Fall 2015, followed by an engineering

evaluation of inspection results.

Ongoing, No

Delays

Anticipated

V.C.11.a.viA program to document citizen complaints and service

requests and the associated corrective actions

NMC

Plan10/31/2015

CRW currently collects citizen complaints and service requests as

detailed in the OMM Section 4.10. CRW developed a Cityworks

data management system, which will document citizen

complaints, service requests, and corrective actions.

CRW is implementing Cityworks for future

management of complaints and service requests.

Cityworks is expected to go on-line by October 31,

2015.

Ongoing, No

Delays

Anticipated

V.C.11.a.vii

A program to identify, prioritize , and schedule remedial works

determined from the findings of the investigations,

evaluations, etc. required within the partial CD to prevent pipe

failure, remove debris creating hydraulic bottlenecks, reduce

I/I, and limit river intrusion.

NMC

PlanOngoing

Based upon the results of the interceptor inspections CRW

prepared a prioritized schedule with budgetary costs for the

rehabilitation of the interceptors, as detailed in the 2/25/15

memo submitted to the regulatory agencies and recorded in

Paragraph V.31.a of the Consent Decree.

CRW will review the findings of the collection system

manhole inspection and outfall inspections to

develop and prioritize additional remedial work.

Ongoing, No

Delays

Anticipated

3-4

Consent Decree


Compliance

Status



Deadline in Consent

Decree / Submittal

V.C.11.a.viii A list that identifies and prioritizes equipment purchasesNMC

PlanOngoing

CRW outlined the procedures for purchasing equipment in NMC

Plan Section 1.2.4.

CRW will identify key equipment purchases during

the preparation of the 2016 budget.

Ongoing, No

Delays

Anticipated

V.C.11.a.ix An O&M training programNMC

PlanOngoing

CRW provided details on its training activities in OMM Section

4.12.

CRW will continue to provide training for staff and

further develop their O&M training.

Ongoing, No

Delays

Anticipated

V.C.11.a.xRegularly scheduled regulator and outfall inspections to detect

and document CSO discharge events

NMC

PlanOngoing

CRW conducts daily inspections at each regulator and outfall as

detailed in OMM Sections 4.1 and 4.2.

CRW will continue doing daily inspections, while also

commencing the CAMP Pilot Study.Ongoing

V.C.11.a.xi

A program with SOPs for the remedial, routine, preventative,

emergency, and as-needed maintenance of the conveyance

and collection systems, including

NMC

PlanOngoing

CRW's OMM includes operational procedures and checklists for

inspection activities.

CRW will continue to implement the practices

outlined in the OMM, while also making notes of

necessary improvements.

Ongoing

V.C.11.a.xi.1Inspection and cleaning of catch basins to remove sources of

gate blockages

NMC

PlanOngoing

CRW has an ongoing inlet cleaning and inspection program as

detailed in OMM Section 4.7. From January 2014 through July

2015 CRW cleaned a total of 356 inlets.

CRW will continue to develop its inlet cleaning and

maintenance program based on the findings of the

ongoing system mapping and inspection work.

Ongoing

V.C.11.a.xi.2Inspection, cleaning, and maintenance of sewers and

manholes

NMC

PlanOngoing

CRW inspects and cleans out key manholes on the interceptors

and within the collection system on a regular basis as described in

OMM Sections 4.4 and 4.6, respectively. In 2014 CRW inspected

and partially cleaned all of its interceptors. CRW also developed

bid documents for the cleaning of 33,000 linear feet of

interceptor.

CRW will continue to develop its manhole cleaning

and maintenance program based on the findings of

the ongoing system mapping and inspection work.

CRW is conducting an inspection of all of manholes in

the collection system. CRW will bid and award a

contract for the interceptor cleaning in Fall 2015.

Ongoing

V.C.11.a.xi.3 Inspection and maintenance of each pump stationNMC

PlanOngoing

CRW inspects and maintains their pumping stations multiple

times each day as outlined in CRW OMM Section 4.3.CRW will maintain their existing practices. Ongoing

V.C.11.a.xi.4Procedures to document maintenance problems in the

collection and conveyance system

NMC

Plan10/31/2015

CRW documents all service requests, repairs, etc. on the standard

forms provided in the OMM. CRW developed a Cityworks data

management system that will utilized for future documentation

of maintenance prblems

CRW will implement Cityworks in October 2015

Ongoing, No

Delays

Anticipated

V.C.11.a.xi.5 Identification of the cause of CSOsNMC

PlanOngoing

During their daily regulator inspections CRW personnel check for

CSOs, document, and when possible, remedy the cause of the

overflow.

CRW will continue daily regulator inspections and

implement the CAMP Study in Fall 2016.

Ongoing, No

Delays

Anticipated

V.C.11.a.xi.6

Investigation of sinkholes where sewer system defects are

suspected, and identification and repairs of sinkholes caused

by the collection or conveyance system deterioration

NMC

PlanOngoing

CRW investigated and repaired sinkholes in accordance with

OMM Section 4.9.

CRW will continue to investigate and repair sinkholes

in accordance with OMM Section 4.9, focusing on

sinkholes identified prior to the CD Date of Lodging,

as required under V.G.31.b, and any other sinkholes

that emerge in critical locations.

Ongoing

V.C.11.a.xi.7 inspections of grease traps from facilities with food servicesNMC

Plan

To be

determined

CRW is developing rules and regulations in conjunction with

obtaining the legal authority to implement these measures.

Development of rules and regulations accompanied

by surveillance and enforcement protocol to continue

throughout reporting period.

No Delay

Anticipated

3-5

Consent Decree


Compliance

Status



Deadline in Consent

Decree / Submittal

V.C.11.a.xi.8 Inspections of non-domestic customer facilitiesNMC

Plan

To be

determined

CRW is developing rules and regulations in conjunction with

obtaining the legal authority to implement these measures.

Development of rules and regulations accompanied

by surveillance and enforcement protocol to continue

throughout reporting period.

No Delay

Anticipated

V.C.11.a.xi.9

Annual planning and budgeting procedures to define the

organization, staffing, and resources needed to properly

operate and maintain the collection and conveyance systems.

NMC

PlanOngoing

CRW prepared their annual budget in accordance with OMM

Section 4.12.Complete 2016 budget by 12/31/15

No Delay

Anticipated

V.C.11.a.xi.10

Investigation and minimization of sources of floatables, solids,

or other materials that cause blockages and/or reduce the

hydraulic capacity of the conveyance and collection Systems.

NMC

PlanOngoing

CRW conducts daily regulator outfalls and cleans out inlets to

minimize solids and floatables.CRW will continue their current practices. Ongoing

V.C.11.bMaximize use of storage in the collection system, by

performing the following:

V.C.11.b.i

Investigate the condition and effectiveness of existing

measures to prevent river intrusion in the combined sewer

system and perform necessary maintenance or replacements

to prevent river intrusion

CD 2/10/2016

CRW performed an inspection of the regulator structures in 2013

and initiated an inspection of outfall structures / pipes during the

reporting period.

CRW is currently completing an inspection of all the

outfalls and will provide Outfall Structure Repair and

Schedule by 12/31/15.

No Delay

Anticipated

V.C.11.b.iiConduct an engineering study to identify priority remedial

work to maximize in-pipe storage

NMC

Plan4/1/2018

CRW continues to develop and calibrate an H&H model of its

system.

Development and calibration of H&H model will

proceed toward 4/1/2016 CD deadline. Engineering

study will be initiated upon completion of H&H model

calibration.

No Delay

Anticipated

V.C.11.b.iii

Identify portions of the combined sewer system that

accumulate material and identify frequency for routine

cleaning

NMC

PlanOngoing

CRW performed an inspection (with some cleaning) in all of the

interceptors in 2014. The data was utilized to develop a

comprehensive cleaning program for the interceptors. CRW

prepared bid documents for the interceptor cleaning.

CRW will bid and award the interceptor cleaning

project. In addition, the ongoing manhole inspection

program will identify and prioritize portions of the

collection system for further investigations and/or

cleaning.

Ongoing, No

Delays

Anticipated

V.C.11.b.iv

Identify locations where river intrusion occurs through cracked

and damaged outfall pipes and develop a priority list and

schedule for monitoring and repair/replacement

CD 2/10/2016

CRW performed an inspection of the regulator structures in 2013

and initiated an inspection of outfall structures / pipes during the

reporting period.

CRW is currently completing an inspection of all the

outfalls and will provide Outfall Structure Repair and

Schedule by 12/31/15.

No Delay

Anticipated

V.C.11.c Maximize flow to the AWTF through the following measures:

V.C.11.c.i

Utilize hydraulic modeling/engineering studies to evaluate,

recommend, and support implementation of simple

modifications to the conveyance system to maximize flow to

the AWTF, including the following procedures:

NMC

Plan4/1/2018

CRW continues to develop and calibrate an H&H model of its

system. CRW began the design of upgrades to the Front Street

Pumping Station.

CRW will continue to develop the H&H model and

proceed with the Front St. Pumping Station design

work. Engineering study will be initiated upon

completion of H&H model calibration.

Ongoing, No

Delays

Anticipated

V.C.11.c.i.1Assuring proper performance of all sewers, structures, and

equipment in the Combined Sewer System and AWTF;

NMC

Plan4/1/2018

CRW's ongoing O&M program detailed in the OMM was

employed to ensure proper operation. CRW also performed

multiple field investigations to better define the collection

system.

Continue to operate the system according to the

OMM.Ongoing

3-6

Consent Decree


Compliance

Status



Deadline in Consent

Decree / Submittal

V.C.11.c.i.2

Adjusting CSO diversion weirs or other devices to the degree

possible without causing in-system surcharge or

Building/Private Property Backups to reduce CSO activity;

NMC

Plan4/1/2018 No activities required during this reporting period.

CRW will continue to develop the H&H model which

will be utilized in the future to evaluate possible

control adjustments.

No Delays

Anticipated

V.C.11.c.i.3Evaluating the benefits of any inflow and infiltration (I&I)

reduction projects.

NMC

Plan4/1/2018

Manhole inspection program may also identify areas of high

infiltration/inflow. Recommendations for I/I reduction will be

part of the capacity assessment study.

CRW will begin flow monitoring work within the

sanitary sewer system to quantify infiltration.

No Delays

Anticipated

V.C.11.c.iiAnnually review and revise flow maximization (to AWTF)

procedures

NMC

Plan

March 31,

Annually

During preparation of the Annual Chapter 94 Report CRW

evaluated the AWTF flows. CRW continued with the construction

of the AWTF upgrades.

AWTF construction will be completed and the facility

will be able to better maximize flows through the

facility

Ongoing

V.C.11.d

Eliminate dry weather overflows. Report DWOs by phone to

PADEP within 4 hours and writing within 5 days of becoming

aware it. Report the following in the semi-annual report.

NMC

PlanOngoing

CRW reports all dry weather overflows in accordance with the

guidelines.CRW will continue their current practices. Ongoing

V.C.11.d.iThe number of reported Dry Weather Overflow events that

have occurred;

NMC

PlanOngoing There was one DWO during the reporting period. CRW will continue their current practices. Ongoing

V.C.11.d.ii

A detailed description of the causes of Dry Weather Overflows,

and the actions that CRW has taken and will take in the future

to prevent recurrence;

NMC

PlanOngoing There was a gate blockage, which was removed to stop the DWO. CRW will continue their current practices. Ongoing

V.C.11.d.iiiThe existing methods used for detecting Dry Weather

Overflows and their efficacy;

NMC

PlanOngoing

CRW conducts daily inspections as detailed in OMM Sections 4.1

and 4.2.CRW will continue their current practices. Ongoing

V.C.11.d.iv

The remedial measures taken for pollution deposited in

Receiving Waters or onto the stream banks after a Dry

Weather Overflow;

NMC

PlanOngoing

CRW removes waste material that has accumulated on the

stream banks, if applicable. CRW will continue their current practices. Ongoing

V.C.11.d.v The environmental impacts of Dry Weather Overflow events. NMC

PlanOngoing

The impact to the Susquehanna River would have been negligible

due to the low volume and short duration of this discharge.CRW will continue their current practices. Ongoing

V.C.11.e

Operate and maintain the combined sewer system to control

solid and floatable materials discharged from CSO outfalls

and remove these materials from the stream banks. Conduct

annual evaluations of past performance and implement

corrective actions.

NMC

Plan4/1/2018 CRW crews remove materials from the stream banks.

CRW will conduct an evaluation of their past

performance, and assess a range of corrective actions

during preparation of its LTCP.

No Delays

Anticipated

V.C.11.fImplement public notification procedures set forth in the

NMC Plan.

NMC

Plan8/10/2016 CRW conducted an inventory of all CSO signage in 2015.

CRW will begin developing a Signage Plan (to be

completed by August 10, 2016).

No Delays

Anticipated

V.C.11.f.iInstall and maintain signs at each CSO outfall that notify and

alert the public.

NMC

Plan8/10/2016

As detailed in NMC Plan Section 8.2, there are 42 outfalls with

signage.



No Delays

Anticipated

V.C.11.f.iiInstall warning signs at public stream access points that notify

and alert the public

NMC

Plan8/10/2016 CRW has a large 3'x5' sign at each of two public boat launches.



No Delays

Anticipated

3-7

Consent Decree


Compliance

Status



Deadline in Consent

Decree / Submittal

V.C.11.f.iii

Develop written procedures to provide the public with

information concerning CSO discharge, impacts on water

quality, and CSO locations

NMC 8/10/2016 No activities required during this reporting period.

CRW will begin developing written procedures for

public notification (to be completed by August 10,

2016).

No Delays

Anticipated

V.C.11.f.iv Distribute CSO pamphlets for public education NMC OngoingCRW began the development of their public outreach and

notification program, as described in NMC Plan Section 7.3.

CRW will continue to develop their public notification

program.Ongoing

V.C.11.f.vEvaluate and document CSO public education programs and

community response and develop follow-up plansNMC Ongoing

CRW began the development of their public outreach and



program.Ongoing

V.C.11.f.vi Investigate and document public involvement NMC OngoingCRW began the development of their public outreach and



program.Ongoing

V.C.11.f.viiConsider implementing email and/or text message public

notification systemsNMC 8/10/2016 No activities required during this reporting period.

CRW will begin developing written procedures for

public notification (to be completed by August 10,

2016).

No Delays

Anticipated

V.C.11.gUtilize the following phased approach to characterize CSO

impacts and control efficacy:

V.C.11.g.i

During Phase I, employ visual inspections (once per day at

each regulator and outfall) and other simple methods,

supplemented by characterization and monitoring efforts, to

determine the occurrence and apparent impacts of CSOs.

CD 12/31/2016

CRW inspects the regulator and outfalls daily. Each inspection is

documented on an Interceptor Service Report as outline OMM

Sections 4.1 and 4.2.

CRW will continue to conduct daily inspection of the

regulators and outfalls. Ongoing

V.C.11.g.ii

During Phase II, utilize a combination of visual inspections and

technology (determined by CAMP Study) to accurately

measure the volume, duration, and start/stop time of all CSO

discharges.

CDTo be

determined

CRW prepared a CAMP Study Plan, which was submitted to the

regulatory agencies on May 9, 2015.

CRW will be implementing the CAMP Study in Fall

2016.

No Delay

Anticipated

V.C.11.g.iiiDuring Phase III, implement the approve post-construction

monitoring program. CD

To be

determinedNo activity this period. No activity anticipated this period.

No Delay

Anticipated

V.C.11.g.ivDuring all Phases, record total daily rainfall in at least five

minute increment.CD Ongoing

CRW has been monitoring rainfall for the past year at eight rain

gauge sites, as documented in quarterly technical memorandum

routinely submitted to EPA/DEP

CRW will continue to monitor rainfall at the eight rain

gauges.Ongoing

V.C.11.g.v

CRW shall document the procedures used to collect data for

CSO overflow events and maintain a record of CSO activity and

rainfall.

NMC

PlanOngoing

CRW documents all their procedures related to regulator and

outfall inspections and the occurrence of CSOs on the interceptor

service reports. Rainfall is also recorded as noted above. The data

is compiled in the Combined Sewer Overflow Report, which is

included with the Semi-Annual Report.

CRW will continue to monitor and document each

CSO event. The information will be compiled for the

next Semi-Annual Report concurrently with the

Chapter 94 Report.

Ongoing

3-8

Consent Decree


Compliance

Status



Deadline in Consent

Decree / Submittal

V.C.11.g.vi

Once the H&H model is developed and calibrated it shall be

utilized to characterize and report CSO discharges. Rainfall

data shall continue to be collected from at least six rainfall

gauges, as well as GARR.

CD 4/1/2016


gauge sites. CRW has been employing GARR in accordance with

these requirements. CRW is also developing the initial H&H

Model.

CRW will continue to monitor rainfall from the eight

rain gauges and GARR. CRW will also continue to

develop the H&H model.

No Delay

Anticipated

V.C.12On an annual basis, evaluate the efficacy of NMC Plan and

revise it in redline format.CD Annual

CRW prepared the NMC Plan, which was submitted on August 10,

2015.

CRW will document recommendations for revisions in

the first annual update of the NMC Plan scheduled

for August 2016.

No Delay

Anticipated

V.DMINIMUM CONTROL MEASURES - STORMWATER

DISCHARGES

V.D.13

Submit an MS4 Individual Permit application with a

Stormwater Management Plan with procedures and a

schedule for complete implementation of the MCMs,

including:

CD 10/1/2014

CRW prepared and submitted their MS4 Individual Permit

application on October 1, 2014. The application included a

Stormwater Management Plan and Paxton Creek TMDL Strategy.

CRW is collaborating with neighboring municipalities

to employ a watershed based approach for the

Paxton Creek TMDL Strategy, which will be

completed by December 31, 2015.

Complete,

Ongoing TMDL

Strategy

Updates

V.D.13.a

Develop a map of the MS4 with all the outfalls identified;

develop a list of priority areas for illicit discharge detection and

conduct inspections/screenings; and report on illicit discharge

detection and elimination efforts.

SWM

Plan

First Year of MS4

Permit Coverage

CRW prepared an MS4 outfall map, which was included with the

permit application. CRW also conducted field investigations to

identify outfalls and map the MS4 system.

CRW is continuing with field investigations to identify

outfalls and map the MS4 system. The findings will be

utilized to update the MS4 outfall map.

Ongoing, No

Delays

Anticipated

V.D.13.b

Develop and implement a program for reviewing post-

construction storm water runoff BMPs, inspecting BMP

construction and maintenance, and maintaining an inventory

of postconstruction BMPs.

SWM

Plan

First Year of MS4

Permit Coverage

CRW has been conducting stormwater management plan reviews

through coordination with the City of Harrisburg. CRW has also

developed draft rules and regulations for stormwater

management. CRW is also pursuing an MOU with the Dauphin

County Conservation District.

CRW will continue to update the rules and

regulations.

Ongoing, No

Delays

Anticipated

V.E LONG TERM CONTROL PLAN DEVELOPMENT

V.E.14

Complete a revised and updated LTCP, including schedules,

deadlines, and timetables for remedial measures to meet the

following goals:

V.E.14.a

Bring all CSO discharge points into full compliance with the

technology based and water quality-based requirements of the

CWA; and

V.E.14.bminimize the impacts of CSOs on water quality, aquatic biota,

and human health.

CD 4/1/2018 Provided under Progress to Date for V.E.15 through V.E.26Provided under anticipated activities for V.E.15

through V.E.26

Ongoing, No

Delays

Anticipated

3-9

Consent Decree


Compliance

Status



Deadline in Consent

Decree / Submittal

V.E.15Implement the final IFMMPP and complete the following

activities:

V.E.15.aMap and inspect the condition of the combined and separate

sanitary sewer systems;

V.E.15.bDivide the combined and separate sanitary sewer systems into

sewersheds and catchments;

V.E.15.c

Upgrade the flow meters measuring from the satellite

communities and continue to utilize the upgraded meters

throughout the CD;

CD 12/31/2015CRW updated the flow meters at the commencement of the

IFMMPP.

CRW will continue to utilize the upgraded flow

meters.Complete

V.E.15.dInstall, utilize, and maintain at least six continuously recording

rainfall gauges and procure GARR;CD Ongoing


gauge sites. CRW has been employing GARR in accordance with

these requirements.

CRW will continue to monitor rainfall from the eight

rain gauges and GARR.

Complete,

Ongoing

V.E.15.e

Install flow monitoring devices on major trunk sewers tributary

to thirteen critical CSO outfalls and on nine interceptor sites,

which are both identified in the IFMMPP, and monitor and

collect data for a minimum of 12 months;

CD

Ongoing,

complete by

11/1/2015

CRW installed and monitored flow meters durign 3rd Quarter

2014 at 13 sites in the combined sewer system and 13 sites on

the interceptors for the past twelve months.

Complete flow monitoring at 13 trunk sewer sites;

continue monitoring at 8 of the 9 interceptor sites.

Complete,

Ongoing

V.E.15.fPrepare quarterly technical memoranda documenting the

results and quality of the flow monitoring data;CD

10/1/2014

through

10/1/2015

CRW submitted technical memoranda for the first two

monitoring quarters.

Submission of the two last quarterly reports. CRW

received confirmation from the Plaintiffs that the

quality of the data is adequate to complete

monitoring.

Complete

V.E.15.g

Utilize rainfall and flow monitoring data to revise, calibrate,

and validate the H&H model using the EPA SWMM 5 modeling

platform. H&H model shall include the entire conveyance

system, combined collection system trunk sewer greater than

42-in in diameter, and an additional 10% of the system, which

shall include 15-20 percent of the combined sewer system and

portions of the separate sanitary sewer system;

CD 4/1/2016CRW has developed the initial H&H model based upon these

guidelines.

CRW will continue to develop, calibrate, and validate

the H&H model.

Ongoing, No

Delay

Anticipated

V.E.15.hPrepare a Sewer System H&H Model Report with the

requirements outlined in the CD; refer to the CD. CD 4/1/2016 No action required during this reporting period. CRW will continue to develop the H&H model.

No Delay

Anticipated

V.E.16

Identify pollutants of concern for each receiving water and

evaluate the LTCP approach options (presumptive or

demonstration) for each receiving water

CD 12/31/2014CRW prepared and submitted the LTCP Approach and Pollutants

of Concern memorandum on December 23, 2014. No activity anticipated this period. Complete

NMC

Plan4/1/2016

CRW continued to develop the GIS mapping of their combined



maps, (2) MS4 field investigations, (3) aerial survey of all surface

structures, and (4) hiring a contractor to perform manhole

inspections within the entire collection system. As the GIS

mapping was developed it was utilized to update the sewershed

delineations.


completed by 12/31/15. The data will be utilized to

revise the connectivity of the pipe networks in GIS.

Ongoing, No

Delays

Anticipated

3-10

Consent Decree


Compliance

Status



Deadline in Consent

Decree / Submittal

V.E.17

Prepare a Water Quality Modeling Plan if the demonstration

approach will be utilized in one or more receiving waters,

which shall include the following:

V.E.17.a Water quality modeling software to be employed;

V.E.17.bModel configuration, including reaches to be modeled and

segmentation and boundary conditions;

V.E.17.c

Calibration and validation, including events and data to be

employed, quantitative and qualitative calibration criteria, and

utilization of H&H Model outputs;

V.E.17.dUse of the Water Quality Model to evaluate Typical Year in-

stream conditions for each identified pollutant of concern;

V.E.17.e

Schedule for model development and implementation,

including integration into LTCP development consistent with

other dates required pursuant to this Consent Decree.

V.E.18

Prepare a Financial Capability Analysis, including sewer rate

setting, service population definition, and median household

income.

CD 4/1/2016 No action required during this reporting period.CRW will begin compiling the information fo the

Financial Capability Analysis.

Ongoing, No

Delay

Anticipated

V.E.19

Prepare a report that addresses sensitive and priority areas in

the receiving waters with documentation of inquiries to state

and federal agencies.

CD 4/1/2016 No action required during this reporting period.CRW will begin compiling the information for the

Sensitive Areas/Priority Areas.

Ongoing, No

Delay

Anticipated

V.E.20

Prepare a report on the statistical evaluation of long-term

rainfall patterns and the identification of a typical year for

the LTCP.

CD 8/1/2015 CRW conducted the typical year evaluation. The typical year memorandum was submitted on

7/29/15.Complete

V.E.21Prepare an Existing System Characterization that includes the

following:

V.E.21.aUtilize the H&H model to characterize CSO discharge events

based on an inter-event period of six hours;

V.E.21.bIncorporate the results of the investigation of priority and

sensitive areas;

V.E.21.c

Characterize the current water quality in receiving waters in

which the demonstration approach is utilized and identify

efforts to identify pollutants of concern;

CD 8/1/2015 CRW prepared the Water Quality Modeling Plan

CRW submitted a Water Quality Monitoring Plan on

July 29, 2015 describing its approach to future water

quality evaluations to support development of the

LTCP.

Complete

CD 4/1/2017 No action required during this reporting period. No activity anticipated this period. No Delay

Anticipated

3-11

Consent Decree


Compliance

Status



Deadline in Consent

Decree / Submittal

V.E.22

Conduct an alternatives evaluation that consists of (1)

identification of feasible CSO control technologies, (2)

evaluation of a wide range of CSO control alternatives and

sizes of each, (3) selection of a suite of proposed CSO controls

to comply with the CWA. Focus on controls for outfalls with

sensitive areas, priority areas, high frequency, or greatest

volume.

CD 4/1/2018 No activity this period. No activity anticipated this period. No Delay

Anticipated

V.E.22.a

Assess the technical feasibility of the following control

technologies: source controls, collection system controls,

storage technologies, and treatment technologies. Separation

and deep tunnel storage shall be included.

CD 4/1/2018 No action required during this reporting period. No activity anticipated this period. No Delay

Anticipated

V.E.22.bIdentify a broad range of CSO controls for detailed evaluation;

refer to CD for details. CD 4/1/2018 No action required during this reporting period. No activity anticipated this period.

No Delay

Anticipated

V.E.22.cConsider GI alternatives as part of the control alternatives;

refer to CD for details. CD 4/1/2018

CRW began development of a Green Infrastructure Plan and

formed three advisory committees to support its development.Continue to develop CRW's Green Infrastructure Plan

No Delay

Anticipated

V.E.23Analyze the LTCP impact on environmental justice

populations.CD 4/1/2018 No action required during this reporting period. No activity anticipated this period.

No Delay

Anticipated

V.E.24The LTCP shall include these specific elements; refer to CD for

details.CD 4/1/2018 No action required during this reporting period. No activity anticipated this period.

No Delay

Anticipated

V.E.25

Any proposal to modify the LTCP development schedule or

the content of the deliverables shall follow the procedures in

Section XIX.

CDTo be

determinedNo action required during this reporting period. No activity anticipated this period.

No Delay

Anticipated

V.E.26After approval the LTCP shall be incorporated into and be an

enforceable part of a modification to this CD or a second CD.CD

To be

determinedNo action required during this reporting period. No activity anticipated this period.

No Delay

Anticipated

V.F SEPARATE SANITARY SEWER SYSTEM COMPLIANCE

V.F.27 Sanitary sewer overflows are prohibited. CD Noted

V.F.28Report SSOs by phone to PADEP within 4 hours and writing

within 5 days of becoming aware it. CD Ongoing CRW reported all SSOs within the collection system.

CRW will begin reporting SSOs on private property

that are caused by the CRW system.Ongoing

V.F.29

Satisfy the following compliance requirements in the

operation and maintenance of the separate sanitary sewer

system:

V.F.29.aThe OMM shall address the O&M of the separate sanitary

sewer system;CD 8/10/2015

CRW's operation and maintenance procedures within the

separate sanitary portion of the collection system are consistent

with those in the combined portion of the collection system, as

outlined in OMM Section 4.6.

CRW will continue to review the OMM and make


update.

Complete,

Updates

Ongoing

3-12

Consent Decree


Compliance

Status



Deadline in Consent

Decree / Submittal

V.F.29.b

The H&H model shall include the portions of CRW's

conveyance system that receive flow from the separate

sanitary sewer system and portions of the separate sanitary

sewer system that have experienced chronic capacity-related

SSOs;

CD 4/1/2016 CRW developed the initial H&H model. CRW will continue to develop, calibrate, and validate

the H&H model.

Ongoing, No

Delay

Anticipated

V.F.29.cThe H&H model shall accurate characterize the dry and wet

weather flows from the separate sanitary sewer system;CD 4/1/2017

CRW began planning for flow monitoring within the separate

sanitary sewer.

CRW will begin flow monitoring in the separate

sanitary sewer system. Findings will be incorporated

into the Separate Sanitary Sewer System Capacity

Assessment

Ongoing, No

Delay

Anticipated

V.F.29.dThe LTCP shall address the portions of the conveyance system

receiving flow from the separate sanitary sewer system. CD 4/1/2018 No action required during this reporting period. No activity anticipated this period.

No Delay

Anticipated

V.F.30 Separate Sanitary Sewer System Capacity Assessment

V.F.30.a

Prepare a Separate Sanitary Sewer System Assessment Plan

that describes an engineering assessment with schedule to

satisfy V.F.30.b.

CD 2/1/2016CRW began planning for flow monitoring within the separate

sanitary sewer.

CRW will begin flow monitoring in the separate

sanitary sewer system and development of its

Capacity Assessment Plan.

Ongoing, No

Delay

Anticipated

V.F.30.bImplementation of separate sanitary sewer capacity

assessment plan; refer to CD for details.CD 4/1/2017 No action required during this reporting period. No activity anticipated this period.

No Delay

Anticipated

V.F.30.c Implement the approved Capacity Assessment Plan CD 4/1/2017 No action required during this reporting period. No activity anticipated this period. No Delay

Anticipated

V.G ONGOING CONSTRUCTION EARLY ACTION PROJECTS

V.G.31Complete the following projects within the timeframes

below:

V.G.31.a

Perform a comprehensive assessment of the structural

integrity of the Front Stet Interceptor, Paxton Creek

Interceptor, Asylum Run Interceptor, and Spring Creek

Interceptor. Identify all priority remedial work and develop a

construction schedule. All priority remedial work shall be

completed by the following dates:

CD 10/31/14; 3/1/5

CRW completed the inspection of 71,000 linear feet of

interceptor in 2014. CRW identified the priority cleaning and

remedial work within the interceptors, which was detailed in a

2/25/15 technical memordandum.

CRW will proceed with bidding and awarding the

cleaning contract for the interceptors and design

contracts for necessary remedial repairs according to

the schedule in the CD.

Ongoing, No

Delay

Anticipated

V.G.31.a.i on the Paxton Creek Interceptor, by December 31, 2017; CD 12/31/2017CRW developed bid documents for the cleaning of this

interceptor in advance of the remedial work.





Ongoing, No

Delay

Anticipated

V.G.31.a.ii on the Asylum Run Interceptor, by December 31, 2018; and CD 12/31/2018CRW developed bid documents for the cleaning of this






Ongoing, No

Delay

Anticipated

V.G.31.a.iii on the Front Street Interceptor, by December 31, 2020. CD 12/31/2019CRW developed bid documents for the cleaning of this






Ongoing, No

Delay

Anticipated

3-13

Consent Decree


Compliance

Status



Deadline in Consent

Decree / Submittal

V.G.31.aPriority remedial work shall include all interceptor segments

that receive a pipe segment score of "5" or "4".CD 3/1/2015

CRW identified and prioritized the remedial work in accordance

with this criteria. No activity anticipated this period. Complete

V.G.31.b

Prepare a list of all sinkholes, investigate all sinkholes reported

as of the date of lodging, provide a schedule for repairs, and

remediate all sinkholes caused by the structural deterioration

of the collection and conveyance systems.

CD 2/10/2018

CRW addressed sinkholes as detailed in the NMC Plan and OMM.

From January 2014 through July 2015, 47 sinkholes were

identfied and addressed by CRW.

CRW will continue to investigate and remediate sink

holes.

Ongoing, No

Delay

Anticipated

V.G.31.cInvestigate each CSO outfall for structure defects, define

priority remedial work, and develop a schedule for the work. CD 2/10/2016 CRW publicly bid the inspection of CSO outfalls inspections.

CRW will complete the outfall inspections and

prepare the CSO Outfall Structure Repair and

Schedule by December 31, 2015.

Ongoing, No

Delay

Anticipated

V.G.31.d

Develop a CSO Activation Monitoring Pilot Study Plan for CSO

activation monitoring technologies in four CSOs for at least 12

months.

V.G.30.d.iEvaluate the efficacy of the technologies in providing remote

real-time regulator status and detecting DWOs.

V.G.31.d.iiThe CAMP Study Plan shall identify the pilot study

technologies.

V.G.31.d.iii Implement the approved CAMP Study Plan

Ongoing, No

Delay

Anticipated

V.H GENERAL COMPLIANCE

V.H.32 Effluent Limits for AWTF.

V.H.32.a Comply with the final effluent limits in the NPDES Permit.CRW reported the two instances where a permit limit was

exceeded to PaDEP.

CRW will continue to fulfill these reporting

requirements.

V.H.32.b The compliance schedule for the AWTF BNR project

construction is as follow:

V.H.32.b.i Issue AWTF NTP by 2/15/14; CD 2/15/2014 Complete; No activity this period. Complete; No activity this period. Complete

V.H.32.b.ii Provide quarterly construction progress reports; CD OngoingCRW submits weekly inspection reports and monthly progress

reports to PADEP.

CRW will prepare and submit a quarterly report by

11/15/15.

Ongoing, No

Delay

Anticipated

V.H.32.b.iii Complete construction by 2/15/16. CD 2/15/2016 The AWTF BNR Upgrade construction progressed as scheduled. CRW will continue the AWTF construction.

Ongoing, No

Delay

Anticipated

V.H.32.cPurchase nutrient credits for the compliance period ending

on 12/30/1411/28/2014

CRW purchased nutrient credits from multiple sources by

11/3/14.

CRW will purchase the necessary quantity of credits

prior to the 11/28/15 deadline for this water year.Complete

CD 5/10/2015CRW prepared a CAMP Study Plan, which was submitted to the

regulatory agencies on May 9, 2015.

CRW will be implementing the CAMP Study in Fall

2016.

Complete

3-14

Consent Decree


Compliance

Status



Deadline in Consent

Decree / Submittal

V.H.33 Dry Weather Overflows

V.H.33.a DWOs are prohibited CD Noted

V.H.33.b Report DWOs by phone to PADEP within 4 hours and writing

within 5 days of becoming aware it. CD Ongoing There was one DWO during the reporting period.


requirements. Ongoing

V.H.33.c When a DWO occurs begin corrective action immediately upon

notification or discoveryCD Ongoing There was a gate blockage, which was removed to stop the DWO.



V.H.33.d Report all DWOs in the semi-annual report. CD Ongoing The DWO is included in the semi-annual report.CRW will continue to fulfill these reporting


V.H.34Unauthorized releases from the combined sewer system are

prohibited.CD Noted

V.H.35Report unauthorized releases by phone to PADEP within 4

hours and writing within 5 days of becoming aware it. CD Ongoing No action required during this reporting period.

CRW will begin to track and report unauthorized

discharges starting with the date the CD became

effective.

Ongoing

V.H.36 Reporting Planned Changes and Non-Compliance.

V.H.36.a

Comply with the provisions of the NPDES permit requiring the

reporting of anticipated and unanticipated non-compliance

with the NPDES permit.

CD OngoingCRW reported the two instances where a permit limit was

exceeded to PaDEP.



V.H.36.bWritten notice of non-compliance shall also be submitted to

EPACD Ongoing

This semi-annual compliance report includes non-compliance

reporting.



3-15


3-17

3.1.3 Legal Authority and Rules and Regulations

Partial CD References: V.B.10, V.D.13.a, V.D.13.b

Following the acquisition of portions of the sewer system that were previously owned and

operated by the City of Harrisburg, it was necessary for CRW to acquire additional legal authority

for the enforcement of activities within the City. In collaboration with the City, entered into an

intergovernmental cooperation agreement to facilitate and assist with environmental compliance.

The Agreement provides CRW with the necessary enforce authority to fulfill their permit and

consent decree requirements, as well as outlines means for cooperation between the two entities.

Additionally, CRW passed interim wastewater rules and regulations on June 25, 2014. CRW

continues to develop new rules and regulations to properly address the requirements of state and

local regulatory agencies for stormwater management. A draft set of rules and regulations was

distributed for public comment on December 19, 2014. CRW is currently coordinating with the

City of Harrisburg on the revised draft stormwater rules and regulations. As outlined in the NMC

Plan, the stormwater rules and regulations will be completed by August 10, 2016

3.1.4 NMC Plan and OMM Development

Partial CD References: V.C.11, V.C.11.a, V.C.11.b, V.C.12

Over a twelve month period, CRW extensively reviewed their existing operations and

maintenance programs, as well as the previous Nine Minimum Controls (NMC) documentation.

CRW also assessed the additional resources and programs that must be developed in order

improve the performance of the collection, conveyance, and treatment systems for stormwater

and wastewater within the City of Harrisburg.

CRW developed a detailed approach to achieve future compliance with each of the NMCs. In many

cases the compliance measures are already implemented, such as daily CSO regulator inspections.

In other areas, additional information is required to implement some of the NMCs and CRW has

undertaken the efforts necessary to collect the data. For example, CRW completed an inspection

of each interceptor, which is critical to understanding and maximizing the capacity of the system.

For other tasks, CRW continues to plan for the implementation of the NMCs, as is the case with

the development of formal public outreach and education program. The complete NMC Plan was

submitted on August 10, 2015. Refer to Table 3.1 for additional details on the specific

implementation of NMC requirements under the partial CD. Appendix A presents the NMC Plan

Summary Table that was included with the NMC Plan and provides details on the current level of

implementation for each NMC, as well as the proposed future actions to achieve full compliance.

CRW reviewed ongoing maintenance and operation efforts and developed improved practices for

compilation in the new Operations and Maintenance Manual (OMM). The OMM defines the critical

equipment and facilities for the AWTF and collection/conveyance systems. The OMM also

includes detailed procedures, complete with checklists, for the following system components:

CSO regulators, outfalls and backflow prevention gates, pump stations, interceptors, force mains,

collection system and manholes, and inlets and catch basins. The OMM also outlines emergency


3-18

procedures, citizen complaint tracking, sinkhole remediation, and education programs. The

document was submitted on August 10, 2015.

From January 1, 2014 to June 30, 2015 CRW’s significant maintenance efforts within the

collection system resulted in the following accomplishments:

�� Cleaned 292 inlets

�� Repaired 105 inlets

�� Repaired 43 sinkholes

�� Responded to 195 customer calls

Additionally, after the purchase of a CCTV truck and equipment in early 2015, CRW maintenance

crews cleaned and televised approximately 4,800 linear feet of sewer during April, May, and June

of 2015.

During the time period of July 1, 2015 to December 31, 2015, CRW staff will be utilizing and

reviewing the NMC Plan and OMM to identify future improvements to the documents.

3.1.5 Conveyance and Collection System Inspection and Mapping

Partial CD References: V.C.11.a.ii, V.C.11.a.iii, V.C.11.a.v, V.C.11.b.i, V.C.11.b.iii, V.C.11.b.iv

CRW has completed the GIS mapping and database for its conveyance system and completed a

preliminary GIS map and database of the combined sewer system, sanitary sewer system, and

separate storm sewer system. This included an aerial and field survey of all surface features, as

well as follow-up field investigations in certain areas. CRW also acquired and reviewed record

drawings and maps for data entry into the GIS database. CRW prepared preliminary sewershed

delineations. The GIS map and database for the collection system will continue to be developed as

additional field investigations, to provide further information on the pipe connectivity, are

conducted in the coming months.

CRW also conducted a field investigation of MS4 manholes and inlets to advance the mapping, and

they are under contract to continue the MS4 mapping in 2016.

CRW inspected approximately 71,000 linear feet of large diameter sewers encompassing all of the

interceptors in 2014. CRW solicited proposals for and awarded a contract for the inspection of all

the manholes within the collection system, which is currently underway. The information

gathered will be vital in further defining the sewershed boundaries, understanding pipe

dimensions and connectivity, and prioritizing the implementation of a comprehensive cleaning

and televising program. This effort will be completed by the end of the 2015, and the data will

also be utilized in the refinement of the H&H model. These inspections also include the

inspections of the CSO outfalls.

CRW also reviewed force main inspection technologies and will be conducting an inspection of

the Front Street PS force main in late 2015.


3-19

3.1.6 Conveyance and Collection System Rehabilitation Planning

3.1.6.1 Reporting Requirements


�� V.G.31.a: Progress on all priority remedial work conducted pursuant to this Paragraph shall

be reported in the Semi-Annual Reports pursuant to Section VII (Reporting Requirements).

3.1.6.2 Progress Update

Partial CD References: V.C.11.a.iv, V.C.11.a.vii, V.G.31.a

CRW evaluated the findings of the interceptor inspections completed in 2014, as detailed in the

February 25, 2015 technical memorandum, to develop a prioritized schedule for cleaning and

rehabilitation projects. CRW began the preparation of public bid documents for the cleaning and

subsequent inspection of 33,000 linear feet of interceptors in June 2015. That project is currently

out for bid, and CRW plans to award the contract in late 2015. This project is the first step

towards implementing the interceptor rehabilitation work.

3.1.7 Cityworks Data Management System

Partial CD Reference: V.C.11.a.vi

CRW has developed a Cityworks data management system for their sewer system. Cityworks will

be implemented in October 2015.

3.1.8 Public Notification



�� V.C.11.f: Public Notification. CRW shall implement the public notification procedures set forth

in the NMC Plan and document their implementation in Semi-Annual Reports submitted under

Section VII of this Consent Decree3.1.7.1 Reporting Requirements


Partial CD Reference: V.C.11.f

CRW conducted an inventory of the existing signage in 2015. As detailed in the NMC Plan, CRW

will develop a signage plan and notification procedures by August 10, 2016.

3.1.9 CAMP Study

Partial CD Reference: V.C.11.g.i, V.g.31.d

CRW completed the CAMP Study Plan on May 8, 2015. It recommends four CSO activation

technologies to pilot based on an assessment of available technologies, and provides an

implementation strategy for the Study. Since the study was submitted, CRW has confirmed

participation of the recommended technology vendors and refined implementation requirements.

CRW will begin implementing the CAMP Study in late 2015, and anticipate an on-time completion

of the study by the December 1, 2016 compliance date in the partial CD.


3-20

3.1.10 MS4 Permitting and Planning

Partial CD Reference: V.D.13

CRW prepared and submitted an MS4 Individual Permit application on October 1, 2014, which

included a Stormwater Management Program and Paxton Creek TMDL Strategy. An MS4 Outfall

map was also provided based upon the information available at the time.

During the next reporting period CRW will be preparing a revised Paxton Creek TMDL Strategy in

conjunction with two of the neighboring municipalities, Lower Paxton Township and

Susquehanna Township, to provide a watershed-based approach. The Strategy will be completed

by the end of 2015.

3.1.11 IFMMPP


�� V.C.11.g.v: The CSO flow monitoring data and rainfall data shall be submitted to the Plaintiffs

in the Semi-Annual Reports required by Section VII of this Consent Decree;


Partial CD Reference: V.E.15, V.F.30.a

CRW prepared and received approval of an Initial Flow Metering and Monitoring Program Plan

(IFMMPP). CRW entered into contracts with flow and rainfall monitoring contractors in 2014. The

monitoring program involves flow monitoring with redundant level measurement at 13 CSO

regulator monitoring sites and 13 interceptor monitoring sites. There are eight precipitation

gauging sites, as well as gauge adjusted radar rainfall. The monitoring period commenced in

September 2014 and has provided data that will be suitable for sewershed characterization and

model validation.

Within the next few weeks the CSO flow monitoring sites will be discontinued and flow

monitoring will commence at six sites within the separate sanitary sewer. This data will be

utilized in the Separate Sanitary Sewer Capacity Assessment.

The flow monitoring and rainfall data was submitted to the Plaintiffs in the first, second, and third

quarterly reports. The fourth quarterly report will be submitted in early October 2015.

CRW plans to maintain the four flow meters monitoring flow from the satellite communities, as

well as eight of the combined sewer interceptor flow meters at the current sites in order to

support flow maximization and storage maximization evaluations.

3.1.12 LTCP Development

Partial CD Reference: V.C.11.g.i, V.E.16, V.E.17, V.E.20, V.F.30.a, V.G.31.d

In support of the LTCP development CRW completed several key tasks during this reporting

period:

�� Prepared the LTCP Alternative Approach technical memorandum based upon a review of

available water quality data and data evaluations. The memorandum recommended


3-21

pollutants of concern for each surface water receiving CSOs, concluded that no independent

collection of water quality data would be necessary to support LTCP development, and

provided a strategy for defining the LTCP approach as H&H modeling proceeds.

�� Prepared a Water Quality Evaluation technical memorandum that further refined the

recommended strategy for determining water quality benefits of the LTCP, building upon

the LTCP approach strategy.

�� Prepared the Typical Year Precipitation memorandum summarizing the methodology used

to develop the typical year precipitation for evaluating existing combined sewer system

performance and evaluating LTCP alternatives.

�� Continued to refine the H&H model to reflect record review and field collection of sewer

system connectivity and attributes; evaluate monitored flow from satellite communities,

and performance data from CRW regulators and pump stations. Model testing, calibration,

and validation will proceed during the next reporting period in order to meet the April 1,

2016 CD compliance date.

�� Selected a contractor and formed stakeholder advisory committees to prepare a Green

Infrastructure Plan as a fundamental element of CRW’s LTCP.

�� Preparation of the Sensitive Areas / Priority Areas technical memorandum, and the

Financial Capability Analysis will begin in the next reporting period in order to meet the

April 1, 2016 CD compliance dates.

3.1.13 AWTF Construction Project

Partial CD Reference: V.H.32.b

The AWTF BNR Upgrade is nearly complete. Almost all excavation and concrete work has been

completed and most heavy equipment will be demobilized by the end of October. Process start-up

and equipment testing will begin in November, and we are anticipating Substantial Completion by

the end of the year. The construction contract ends in March 2016.

3.1.14 Discussion of Issues/Noncompliance



�� VII.A.43.c: A summary of all the problems or potential problems encountered during the prior

six-month period, and the actions taken to rectify the problems;

�� VII.A.43.h:. Disclosure of any non-compliance with the requirements of this Consent Decree,

including: i. An explanation of the likely cause of the non-compliance, or, if the likely cause of

the non-compliance cannot be determined at the time the Semi-Annual Report is due, an

explana

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