2010 Whitefish Bay CMOM Plan

VILLAGE OF WHITEFISH BAY
CAPACITY, MANAGEMENT, OPERATIONS, MAINTENANCE

(CMOM) PLAN
Prepared By:
Superior Engineering, LLC
S75W13139 Oxford Court
Muskego, WI 53150
(414) 235-9726
Version 3
February 25th, 2010
TABLE OF CONTENTS
Manual No. 1
SECTION 1 – Overview ..............................................................................................................1
SECTION 2 – Management Plan................................................................................................4
SECTION 3 – Operation And Maintenance Plans…………………………………………………14
SECTION 4 – Capacity Plan …………………………………………………………………………18
SECTION 5 - Overflow Response Plan …………………………………………………………….20
SECTION 6 - Condition Assessment Program …………………………………………………….22
SECTION 7 - Communication Plan …………………………………………………………………23
SECTION 8 – Audit Plan……………………………………………………………………………...24
APPENDIX A – Reference Stipulation - Satellite Municipalities
APPENDIX B – Reference Stipulation – Milwaukee Metropolitan Sewerage District
APPENDIX C – Reference CMOM Strategic Plan January 2008
APPENDIX D - Overflow Response Plan

1. Table D-1 Sanitary Sewer Overflow and Monitored Sites
2. Table D-2 Emergency Contact Notification
3. Table D-3 Emergency Contractor Notification
4. Table D-4 Mutual Aid Table
APPENDIX E - Forms
1. Sanitary Sewer Overflow or Bypass Notification Summary Report Form 3400-184.
2. Lateral Root Notice to Homeowners
3. Sewer Cleaning Form
4. Public Works Service Request Form
5. Manhole Inspection Form
6. Root Cause Failure Analysis Form
7. MS4 Stormwater Permit Form 3400-191
APPENDIX F – Standard Operating Procedures (SOP)

TABLE OF CONTENTS
1. Wet Weather SOP

2. Critical Manhole Locations
3. Sanitary Sewer Maintenance Procedures
SOP APPENDIX G – References

1. Table G-1 Annual Performance Measurements 2009
2. Cleaning and Root Cutting Schedule 2009-2011
3. Capital Improvements Map Sanitary Sewer
4. Sanitary Sewer Easements
5. Critical Locations in the Village
6. Sanitary Sewer Seal Detail
7. Modeled Sanitary Sewer System Schematic 2006
SECTION 1 - OVERVIEW
1.1 Background and Information
The Village of Whitefish Bay is located in Milwaukee County. The Village serves
approximately 14,000 people through its sanitary sewer system which consists of 204,336
linear feet of 8-inch to 18-inch diameter sanitary sewers and 1 manholes. There are no lift
stations in the Village.
The wastewater from the Village collection system discharges to the Milwaukee Metropolitan
Sewer District (District) via several Metropolitan Interceptor Sewer (MIS) connections. The
District is responsible for treating the wastewater
A Capacity, Management, Operations and Management (CMOM) Plan is required to comply

with the Satellite Stipulation between the State of Wisconsin and the Village of Whitefish Bay
(State of Wisconsin v. Milwaukee Metropolitan Sewerage District, et. al. Case No. 2005-CS-
000013) as well as the stipulation entered between the State of Wisconsin and the District
(Stipulation – State of Wisconsin v. Milwaukee Metropolitan Sewerage District. Case No. 02-
CS-2701). Copies of the applicable portions of the stipulations are included in Appendices A
and B, respectively. The overall intent of the CMOM Plan is to reduce sanitary sewer
overflows (SSOs) in accordance with the regulations.
1.2 CMOM Program Objectives
The Wisconsin Department of Natural Resources (DNR) defines a CMOM program that
achieves these primary objectives:
1. Ensures that communities have adequate wastewater collection capacity.

2. Improves the operation and performance of the municipal sanitary sewer collection
system.
3. Evaluates areas of excessive inflow of precipitation or groundwater into the system.
4. Conducts maintenance and repairs needed to prevent problems.
5. Reduces the frequency and occurrence of sewer overflows and basement backups.
6. Provides more effective public notification when overflows do occur.
In addition to these objectives, an effective CMOM program also:
1. Protects human health including drinking water, swimming, blood-born pathogens,

fishing
2. Protects the local economy by preventing property damage, beach closures, and
enhancing the fishing industry
3. Protect infrastructure investment by properly maintaining the sewers to reduce
emergency repairs and extend the system life
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February 25 , 2010 Page 1
For further information on the background of a CMOM Plan and components, reference the
CMOM Strategic Plan, January 2008 located in Appendix C.
1.3 CMOM Program Components
The CMOM Plan includes the following components:
• Section 2 Management Plan

• Section 3 Operation and Maintenance (O&M) Plan
• Section 4 Capacity Plan
• Section 5 Overflow Response Plan (ORP)
• Section 6 Condition Assessment Program
• Section 7 Communications Plan
• Section 8 Audit Plan
1.4 Definitions
For the purpose of this document the following definitions pertain:
1. CMOM Capacity, Management, Operations and Maintenance. A program to efficiently

operate and maintain collection system assets to minimize performance failures and
overflows.
2. Collection System is defined as the Village sanitary sewer system including sanitary
sewers, manholes and associated equipment.
3. DNR – means the Wisconsin Department of Natural Resources
4. DNR Chapter NR 110 – – Register May 2001, No. 545 – Sewerage Systems “NR 110”.
State of Wisconsin rules for sewerage systems.
5. District is the Milwaukee Metropolitan Sewerage District
6. Infiltration definition from Wisconsin DNR Chapter NR 110 - means water other than
wastewater that enters a sewerage system (including sewer service connections) from
the ground through such sources as defective pipes, pipe joints, connections, or
manholes. Infiltration does not include, and is distinguished from, inflow.
7. Inflow definition from Wisconsin DNR Chapter NR 110 - means water other than
wastewater that enters a sewerage system (including sewer service connections) from
sources such as roof leaders, cellar drains, yard drains, area drains, foundation drains,
drains from springs and swampy areas, manhole covers, cross connections between
storm sewers and sanitary sewers, catch basins, cooling towers, storm waters, surface
runoff, street wash waters, or drainage. Inflow does not include, and is distinguished
from, infiltration.
8. I/I is the abbreviation for Infiltration/Inflow
9. Sanitary sewer overflow (SSO) is a condition whereby untreated sewage from the
Village sanitary sewerage collection system is discharged into the environment prior to
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reaching treatment facilities thereby escaping wastewater treatment. It is also

considered a discharge of sewerage to waters of State. When caused by rainfall it is
also known as wet weather overflow. SSO is also referred to as “confirmed sewage
spill”, “sewer overflow,” or “overflow”.
10. Satellite Municipality is a municipality that is served by the District. The Village of
Whitefish Bay is considered a satellite municipality.
11. Stipulation. Satellite Stipulation between the State of Wisconsin and the Village of
Whitefish Bay. See Table 1-1 for a summary of the Village requirements.
12. Village – Village of Whitefish Bay
1.5 Stipulation Summary
As noted previously, the Village’s Stipulation with the State of Wisconsin is included in
Appendix A. Some of the general provisions required under the Stipulation are outlined in
Table 1-1.
Table 1-1 Stipulation Summary – Village of Whitefish Bay

Section Description Deadline Complete
No.
17 Flow Monitoring and Rain Gauges – District Ongoing Ongoing
18 Enforcement of Sewer Use Ordinances Ongoing Annually
19 Defects 2010 Limited SSES Study 12/31/2006 Yes
20 Inspect Manholes for Ponding 9/30/2006 Yes
21 Inspect Manholes on a five year basis 6/30/2006 Annually
22 CMOM Plan 6/30/2009 Draft May
2009
31 Submit SSO investigation for the SSOs at N. 1/31/2007 Yes
Newhall & E. Chateau Place and N. Diversey
Blvd and E. Lancaster Avenue
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SECTION 2 – MANAGEMENT PLAN
2.1. Background and Information
A Management Plan describes the approach that the Village is undertaking to implement their
CMOM Plan. The Management Plan consists of the following components.
1. Mission Statement
2. Goals
3. Organization
4. Management of Assets
5. Customer Service
6. Legal Authority
7. Fiscal
8. Data Management
9. Standard Design, Construction and Inspection
10. Training
11. Performance Measurements
2.2. MISSION STATEMENT
The Village of Whitefish Bay developed a mission statement for their CMOM Program.
MISSION STATEMENT
To Cost Effectively Collect And Convey All Of Our
Customers’ Wastewater In Accordance With Applicable Law.
To protect the Health, Safety and Overall Environment of our

Community.
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2.3. GOALS
The Village of Whitefish Bay strives for continuing and long term goals. Note that the goals in
BOLD are required by District. See Table 2-5 linking goals with performance measures
1. Comply with WPDES permit
2. Minimize the occurrence of problematic overflows
3. Improve or maintain system reliability
4. Maintain assets cost-effectively through a rehabilitation and replacement program

based on condition assessment
5. Provide first-class customer service
6. Reduce the potential threat to human health from sewer overflows
7. Protect collection system worker health and safety
8. Provide adequate capacity to convey peak flows
9. Manage Infiltration and Inflow
10. Operate a continuous CMOM Program
2.4. Organization Structure
The Village owns and operates the wastewater collection system and currently does not have
one full-time person assigned to the Collection Systems due the size of the community. To
efficiently execute a CMOM program, it is necessary to identify employees that are
responsible to implement the CMOM programs and to report sanitary sewer overflows. The
Village will review staffing and out-sourcing services on a regular basis to determine if the
CMOM Program is properly administered. The different program elements are managed as
follows: See Table 2-1 for Village staff responsibilities and Figure 2-1 for the Village
organization chart as it relates to the collection system.
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Table 2-1 Village Staff Responsibilities

Title Responsibilities
Village Manager Reports to the Village Board and manages all personnel,
procurement, budget and overall operation of Village
activities including the collection system.
Director of Public Works Responsible for CMOM Program. Is also responsible for
the Collection Systems and all other functions of the DPW.
Assistant Village Engineer Manages special projects including collection system
projects
Engineering Technician Responsible for maintaining maps and other documents
for the Village
DPW Superintendent Responsible for managing Service Workers .
Crew Leader Responsible for day-to-day activities in the field
Service Workers Responsible for cleaning and inspecting the sewers and
other maintenance activities
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2.5. Management of Assets
Managing assets cost-effectively is a key CMOM program goal.
2.5.1. The Village has a comprehensive Capital Improvements Plan which is updated on
an annual basis. The Village also has a three year sanitary sewer improvement
plan that identifies specific projects to be completed. See Plan in Appendix G.
2.5.2. Village currently uses paper forms to track all activities. An example of each form
can be found in Appendix E. The Village reviews and updates these forms on a
regular basis.
2.5.3. Maps
2.5.3.1. The Village has updated their sanitary sewer map showing key assets
including sewers and manholes.
2.5.3.2. The Village tracks many maintenance activities using sewer maps. These
maps can be found in Appendix G.
2.5.4. Operation and Maintenance Programs – See Section 3 for more details.
2.5.5. Condition Assessment Program. The Village currently has a program to evaluate
the condition of the Village assets. This assessment is used to budget and plan for
upcoming rehabilitation, repair and replacement programs. See Section 6 for more
details.
2.5.6. Equipment and Spare Parts. To perform routine operations and maintenance,
respond to emergencies and prevent sanitary sewer overflows, it is critical to have
adequate equipment. In addition, spare parts for certain equipment items have
been identified for emergencies. A list of equipment and spare parts that the Village
owns and maintains can be found in Table 2-2.
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Table 2-2
Village Of Whitefish Bay Equipment And Spare Parts
Mfg/ Year
Description Qty Capacity/Size
Model Purchased
EQUIPMENT
Sewer Combo Truck VacCon 1 9 cubic yard debris box 1998
Inspection Truck 1
Aries Pan and tilt - wheel
Camera 1 2007
Pathfinder driven for 6-24" pipe
Portable Pump Wacker 2 4", 16HP 705 gpm
Portable Pump Wacker 2 3", 8 HP, 425 gpm
Portable Generator None
2.5.7. The Village has also identified critical sewers in their system. These are identified
below and in Table 2-3 – Sanitary Sewer Overflow and Monitored Sites.
• North Lake Drive Sewer

• Lydell Sewer
• Santa Monica Road Sewer
• Silver Spring Sewer
• Hampton Road Sewer
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Table 2-3
Village of Whitefish Bay Sanitary Sewer Overflow and Monitored Sites
Manhole
No. Manhole Location Site Type Receiving Point Description
WB 16 Circle Drive (near public Overflow Site Storm Sewer on Circle, to Lake
walk to Marlborough) Valved Michigan (Silver Spring Outfall)
WB 20 Overflow Site Storm Sewer on Lake Dr, to Lake
Lake Drive @ Lake View Duck Bill Valve Michigan (Silver Spring Outfall
WB 1 Overflow Site Storm sewer on Montclair, to Lake
Montclair & Kent Gravity Pipe Michigan (outfall n/o Klode Park)
Montclair & Bayridge Gravity Pipe Michigan (outfall n/o Klode Park)
WB 7 Montclair & Santa Overflow Site Storm sewer on Montclair, to Lake
Monica Gravity Pipe Michigan (outfall n/o Klode Park)
Montcalir &Berkeley Gravity Pipe Michigan (outfall n/o Klode Park)
WB14 Overflow Site Storm sewer on Montclair, to Lake
Montclair & Lake Dr Gravity Pipe Michigan (outfall n/o Klode Park)
Monrovia & Lake Valved Michigan (outfall n/o Klode Park)
WB 19 Overflow Site Storm Sewer on Lancaster, to
Diversey & Lancaster Gravity Pipe Milwaukee River @Estabrook Park
WB 26 Overflow Site Storm Sewer on Hampton, to
Sheffield & Hampton Valved Milwaukee River @Estabrook Park
WB 18 Overflow Site Storm Sewer on Newhall, to Lake
Newhall & Fairmount Gravity Pipe Michigan (Buckley Park Outfall)
WB 23 Overflow Site Storm Sewer on Lake Dr, to Lake
Oakland & Lake Dr Gravity Pipe Michigan (Buckley Park Outfall)
Overflow Site Storm Sewer on Wilshire, to Lake
MH 157 Wilshire & Cumberland Gravity Pipe Michigan (Buckley Park Outfall)
Overflow Site Storm Sewer on Newhall, to Lake
MH 91 Newhall & Chateau Gravity Pipe Michigan (Buckley Park Outfall)
Monitored Site Storm Sewer on Idlewild to Lake
MH 88 Lexington & Idlewild Portable Pump Michigan (Silver Spring Outfall)
Monitored Site Storm Sewer on Cramer, to Lake
MH 162 Wilshire & Cramer Portable Pump Michigan (Buckley Park Outfall)
2.6. Customer Service
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How the Village delivers service to its customers is critical for effective CMOM program. The
program is monitored based on how quickly can the Village respond and resolve the problem.
Tracking these issues is critical to determine problems in the field including problems related to
customers laterals (customer obligation) versus Village. The Village has a Public Works
Service Request form and is using this as a tool to address problem areas and ensure that the
work is documented. A copy of this form can be found in Appendix E.
The Village website is used to inform their customers of Staff contacts, upcoming projects,
ordinances and newsletters.
See Section 7 Communication Plan for other details related to communications.
2.7. Legal Authority
Legal authority consists of the Village codes and ordinances and the enforcement of codes
and ordinances. The Village reviews and updates their ordinances on a regular basis. All
ordinances are available on the Village website. The Village currently has the following
ordinances:
• Sanitary Code – Chapter 10
• Plumbing Code – Chapter 13
• Maintenance of Property – Chapter 18
2.7.1. Sewer Use/Sanitary and Plumbing Codes
2.7.1.1. The Village will review their ordinance on a regular basis to modify as
necessary revised regulations and to ensure clear water from other sources is
not entering the collection system. The ordinance evaluates the use of public
and private sewers and drains in to the public sewerage system within the
Village.
2.7.1.2. The regulation requires individual property owners to maintain sewer service
from the street main to the property and to prevent unnecessary
overburdening of the sewer system. Village has the legal authority to require
homeowners to comply with the regulation.
2.7.1.3. The Village is committed to enforcing their ordinance to ensure that clear water
is not entering the system.
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2.7.2. Fats, oil and grease coat, congeal, and accumulate in pipes, leading to costly and
hazardous flow of grease into laterals, sewers, entering the collection system can
accumulate on sewer pipe walls causing blockages and foul odors in the sewer
system. Fat, oil and grease in the sewers is typically from improper management of
grease traps in food establishments such as restaurants, schools, and coffee
shops.
2.7.2.1. To prevent blockages in the sewer, the Village performs maintenance cleaning
on a regular basis for areas that discharge wastewater from food preparation
places.
2.7.2.2. The Village continues the inspection of grease traps in food preparation places
to ensure that grease is not discharged to the sewers.
2.7.2.3. Grease traps or separators must be properly maintained and cleaned on a

regular basis to properly remove grease. The food establishment needs to
document the maintenance and cleaning.
2.7.3. The Village also complies with the following:

• District rules and regulations
• The State plumbing code - Wisconsin Administration Code chapter COMM. 82.
• DNR requirements including Whitefish Bay WPDES Permit
2.8. Fiscal programs
The Village currently charges a sewer fee based on water consumption and has consistently
raised the sewer rates to fund the operation and maintenance and capital improvements in the
collection system. This rate is reviewed annually. The Village also uses the following factors
to review rates:
• O&M Programs - see Section 3.
• Condition Assessment Programs - see Section 6.
• Recommendations to reduce I/I.
• Capital Projects
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2.9. Data Management
2.9.1. The Village currently uses paper forms to track all maintenance activities including
inspection, cleaning, rehabilitation and replacement projects. An example of the
forms used can be found in Appendix E. The Village reviews and updates these
forms on a regular basis.
2.9.2. The Village uses electronic maps to track maintenance activities including future
schedules.
2.10. Standard Design, Construction, and Inspection
2.10.1. The Village uses a consultant for sewer designs. Standard specification for sewer
and water construction in Wisconsin, latest edition is used.
2.11. Training and Education
2.11.1. Safety. The Village uses a consultant to provide safety training on a regular basis.
2.11.2. Equipment and Tools. The Village uses vendors and equipment manufactures for
training.
2.11.3. Professional Training. The Village budgets for employees to attend local training for
collection system skills.
2.12. Performance Measurements
2.12.1. The Village has various performance measures that are monitored on a regular
basis. These measurements are found in Table 2-4 and in Table G-1.
2.12.2. These performance measures are based on the following:

• The Stipulation
• District Rules
• DNR Requirements
• Village Goals
2.12.3. An annual review of the performance measures will be done to compare actual
versus planned. See Section 8 – Audit Plan for more details.
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Table 2-4
Village of Whitefish Bay Performance Measures
DESCRIPTION GOALS**
SEWERS
Total Sewer Length in Feet 204,336 feet
Sewers cleaned (Feet/year – ft/yr) 20% 40,870 ft/yr
Sewers inspected 20% 34,737 ft/yr
MANHOLES (MH)
Number of Manholes in System 906 Manholes
Manholes inspected 20% 181 MH/yr
REHABILITATION/REPLACEMENT DESCRIPTION
Numbers of manholes repaired TBD MH
Number of manholes replaced TBD MH
Sewer Rehabilitated (Lined, Grout, Point Repair) TBD feet
Sewer Replaced TBD feet
MAINTENANCE ACTIVITIES
Root Removal TBD feet
Smoke Testing TBD %
Dye Water Flooding TBD %
Flow Monitoring percent of the collection system TBD %
TRAINING
Compliance with Wisconsin Administrative Code Comm 32
STIPULATION
Compliance with the Stipulation
REPORTING
Reporting requirements per Section 8
Number of basement backups from Village sewers 0
Number of basement backups from Private property laterals 0
Total number of backups 0
Number of Sanitary Sewer Overflows 0
**See Recommended Annual Performance Measures in Appendix G
Note 1
The Village of Whitefish Bay “agree[s] that they will encourage and
support MMSD’s continuing development, implementation, and
management of flow monitoring and rain gauge systems and peak flow
performance standards." The Village "retains all legal rights to object to
and appeal any rules and standards implementing such MMSD activities.
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Table 2-5 CMOM Program Goals, Objectives, Regulatory Expectations and Performance Measures
Program Goals Objectives Regulatory Expectations Performance Measures (PMs)
1. Comply with the WPDES Ensure procedures are Untreated wastewater Number of Sanitary Sewer
permit concerning sanitary in place to identify discharges from the Overflows
sewer overflows SSOs, report SSOs to system are a violation of
the WDNR, and the WPDES permit.
mitigate impacts from
the SSOs per the
WPDES permit.
2. Minimize the occurrence Ensure procedures are The WDNR General Permit Inspect sewers and manholes
of problematic overflows in place including O&M for SSOs provides specific
practices to minimize circumstances under which Rehabilitate or replace sewers and
overflows the WDNR may not take manholes
enforcement action against Perform maintenance activities
the discharger. These
circumstances include
situations where the SSO
occurred to prevent loss of
life, personal injury, or
severe property damage.
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3. Maintain assets cost Ensure preventive State statutes require Inspect sewers and manholes
effectively maintenance is wastewater rates to include
performed (pump a component for equipment Rehabilitate sewers and manholes
stations, manholes, and replacement.
sewer pipes)
Continue to conduct
condition assessments
on sewer assets.
4. Provide first class Ensure Customer Number of customer complaints

customer service Service program is
meeting the Village
needs
5. Improve or maintain Confirm the existence Inspect sewers and manholes

system reliability of any system
components that do not Rehabilitate sewers and manholes
function according to Perform maintenance activities
established reliability
standards.
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6. Reduce the potential Identify potential Overflows from the system Reporting PMs
threat to human health from overflows are a violation of the
sewer overflows WPDES permit, Clean Inspect, replace and rehabilitate
• Confirm the Water Act, and Wisconsin sewers and manholes
existence of
State law.
locations where
system overflows
could pose a threat
to human health.
• If such locations
exist, develop
response measures
and investigate
alternatives for
eliminating the
potential threat.
7. Provide adequate Gain an understanding The State would require a Perform flow monitoring as
capacity to convey peak flow of the current system’s System necessary
ability to convey peak Evaluation/Capacity
flows and what steps Assurance Plan for the Rehabilitate and replace sewers
are necessary to Village if the evidence and manholes
address system shows that the system
inadequacies. does not possess the
capacity to convey peak
flows .
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8. Manage infiltration and Reduce I/I If the State or MMSD Inspect sewers and manholes
inflow determines a SECAP is
• Understand the required of the Village, a Rehabilitate sewers and manholes
current level of I/I in
component of this plan will Perform maintenance activities
the system, the
extent to which it include I/I evaluation and
poses a threat to reduction.
the regional or
municipal system
operation, sources
of I/I, and potential
remedial measures.
• Establish a program
to reduce I/I in
situations where I/I
results in service
problems, overflows
and building sewer
backups. Such
performance
standards may
include those that
would prevent I/I
from increasing in
the future.
9. Protect collection system Provide a safe working Compliance with WI Administrative
worker health and safety environment for all Code Comm 32
employees.
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10. Operate a continuous Establish procedures Update Plan Yearly

CMOM Program for monitoring CMOM
Program Report per Table 8-1
implementation and
initiating program
modifications.
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SECTION 3 – OPERATION AND MAINTENANCE PLANS
Operation and Maintenance (O&M) Programs for the collection system is critical to properly
operate and maintain the collection system and to provide recommendations for future
rehabilitation and replacement projects. The Village has historically inspected and cleaned
sewers and manholes on a routine basis. These inspection programs are necessary to
determine structural integrity, root problems, illegal connections, and I/I problems. In addition,
several other programs are used on an as-needed basis to maintain the system.
The Village has the following O&M Programs:
1. Inspection of Sewers
2. Inspection of Manholes
3. Inspection of Easements
4. Inspection of Critical Structures
5. Code Compliance
6. Sewer Cleaning
7. Smoke Testing
8. Dye Water Flooding
9. Root Control
3.2 Inspection - Sewers
3.2.1 The sewer inspection cycle will be performed initially on a five year cycle. Annually
sewers are identified to be inspected. Based on the results of these inspections,
the inspection cycle may be revised and future inspections could result in some
areas inspected more frequently or less frequently than other areas.
3.2.2 Sewer inspections will be done by using a closed circuit television camera (CCTV).
3.2.3 All sewer inspections are documented a copy of the form used can be found in
Appendix E.
3.2.4 Sewer inspections will be used for to assess the condition of the sewer. See
Section 6 for details. Based on the rating of the assessment, a recommendation
shall be made for future inspection and cleaning schedules and for repairs,
rehabilitation or replacement for the collection system.
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3.3 Inspection - Manholes
3.3.1 The Village of Whitefish Bay inspects manholes on a regular basis. Per the
Stipulation, manholes are required to be inspected once every five years or 20
percent per year.
3.3.2 Manhole inspections shall be documented a copy of the form used can be found in
Appendix E.
3.3.3 Manhole inspections will be used for to assess the condition of the manhole. All
defects shall be replaced within 18 months in accordance with the Stipulation.
3.3.4 Manholes were inspected previously to determine if there was any ponding on
manholes. This was required per Section 20 of the Stipulation. All defects were
corrected. .
3.3.5 Based on the condition assessment rating, recommendations shall be made for
future inspections, rehabilitation or replacement. See Section 6 for Condition
Assessment information.
3.4 Inspection of Easements
3.4.1 The Village currently sewers located on easements or private property. It is

important to keep these areas clear to ensure that access to all manholes is
available for maintenance activities and emergencies. The Village has a map
showing these easements in Appendix G. There is an on-going inspection program
to ensure sewers and manholes are accessible.
3.5 Inspection of Critical Structures
3.5.1 The Village also performs other inspections for critical structures in the system as
necessary. These can and will vary upon the situation. Critical structures are
identified in Section 2.5.7 and Table 2-3.
3.6 Code Compliance
3.6.1 Properties are inspected for compliance with the ordinances and codes. The
Village is committed to enforcing the ordinances and codes.
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3.7 Sewer Cleaning Program
3.7.1 The Village has a sewer cleaning program to remove debris from the sewers and to
prevent blockages and potential sewer backups or SSOs. A copy of the form can
be found in Appendix E.
3.7.2 The sewer cleaning cycle will be performed initially on a five year cycle. Annually
sewers are identified to be cleaned. Based on the results of the cleaning and
inspecting the sewers, the cleaning cycle may be revised. Future inspections
could result in some areas cleaned more frequently or less frequently than other
areas.
3.7.3 Other areas that may require more frequent cleaning are included in the cleaning
schedule. These locations may change based on projects completed in the Village.
These locations are shown on the Sewer Map – G-2 – Critical Locations in the
Village.
3.8 Smoke Testing Program
3.8.1 Smoke testing is another element that the Village uses to identify sources of I/I and
potential defects.
3.8.2 On a regular basis, this will be reviewed to determine if smoke testing is

recommended.
3.8.3 Smoke Testing Procedure
3.8.3.1 Notify the Police and Fire Department when performing smoke testing.
3.8.3.2 This testing is not to be performed when the ground is frozen and it prevents
the smoke from penetrating the soil and identifying leaks.
3.8.3.3 Typically smoke testing will be contracted out due to the resources and
equipment necessary to successfully perform this task.
3.9 Dye Water Flooding
3.9.1 Dye Water Flooding is another element that the Village uses to identify sources of
I/I.
3.9.2 Dye Water will be used on an as-needed basis.
3.9.3 Dye Water Flooding Guidelines:
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3.9.3.4 Notify the Police and DNR prior to doing dye water flooding to let them
know that the water will be colored in the event that it reaches navigable
waters.
3.9.3.5 This testing should not to be performed when the ground is frozen and it
prevents the water from penetrating the soil and identifying leak
3.9.3.6 Typically dye water flooding will be contracted out due to the resources and
equipment necessary to successfully perform this task.
3.10 Root Control
3.10.1 Root intrusion in collection systems is another source of blockages and overflows.
Control of roots will be done in combination with routine cleaning to reduce
blockages and overflow.
3.10.2 Root Control is scheduled with the cleaning. See Appendix G for Root Cutting Map.
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SECTION 4 – CAPACITY PLAN
The Village is required to have sufficient capacity during dry weather events and to manage
peak wet weather flows. This includes identifying areas during wet weather events where
excess flow from I/I occurs. The Village is land-locked and fully developed. There is minimal
or no redevelopment. Future flows are anticipated to remain the same.
4.2 Capacity
4.2.1 Dry Weather Conditions. The Village has no dry weather capacity restrictions.
4.2.2 Wet Weather Conditions. The Village will continue to reviews flows during wet
weather events to reduce I/I. Problems during wet weather events and SSOs are
analyzed to determine the root cause of these problems. A root cause failure
analysis form is included in Appendix E.
4.2.3 The Village has an on-going inspection program to identify I/I.
4.2.4 The Village is enforcing their ordinances on a continuous basis to ensure that I/I is
reduced.
4.3 Capital Improvements
4.3.1 The Village has a five year capital improvements plan (CIP). Projects have been
identified from the O&M Programs defined in Section 3.
4.3.2 The Plan includes projects to reduce peak wet weather flows.
4.4 Field Investigation
4.4.1 The Village performs field investigations on a regular basis to identify I/I, defects
and other potential problems. All problems are based on: customer service
requests; staff recommendations; or as needed.
4.4.2 Problem areas and overflows are investigated. Overflows are reported – See
Section 5 Overflow Response Plan and Appendix D for more details.
4.4.3 Observations and recommendations from these field investigations are used to
enhance the O&M programs and to provide repair, rehabilitation and replacement
recommendations.
4.5 Flow Modeling
4.5.1 The Village currently does not use flow modeling to evaluate the collection system.
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SECTION 4 – CAPACITY PLAN
4.5.2 Flow modeling may be considered if the Village determines that it is necessary to
manage peak wet weather flows.
4.6 Flow Monitoring
4.6.1 The Village will use the District flow monitors to evaluate flows in the system and to
evaluate capacity constraints.
4.6.2 Additional flow monitoring may be done on a case-by-case basis to identify high I/I
areas and to confirm flows in the system.
4.7 I/I Reduction
4.7.1 The Village continues to address I/I reduction on a regular basis .
4.7.2 Village properties were mostly constructed with building foundations connected to
the sanitary sewer or combined sewer. Current plumbing code requirements
require building foundations to be connected to a sump pump or storm sewer,
however existing properties were not required to update the plumbing to current
standards.
4.7.3 Rehabilitation and replacement programs are based on reducing I/I in addition to
ensuring that the structural integrity of the assets is maintained.
4.7.4 Projects are included in the Village CIP for planning and financing purposes.
4.8 Peak Flow Performance Standards
Pursuant to the Stipulation between the State of Wisconsin and the Satellite
Municipalities, the Village “agree[s] that [it] will encourage and support MMSD’s
continuing development, implementation, and management of flow monitoring and rain
gauge systems and peak flow performance standards.” The Village “retains all legal
rights to object to and appeal any rules and standards implementing such MMSD
Activities.” Refer to Table 2-5 and Appendix G-1 for additional information.
t h
SECTION 5 –OVERFLOW RESPONSE PLAN
An Overflow Response Plan (ORP) is necessary to protect public health and the environment.
It provides procedures to respond to overflows, documents work and reports notification to the
appropriate parties. The ORP is a standard operating procedure (SOP) and the SOP is
included in Appendix D. A summary of the Plan is included in this section.
5.2 Procedure
5.2.1 The Village has an ORP that is updated on a regular basis and is included in
Appendix D- Overflow Response Plan. This includes:
• Procedures to respond to SSOs
• Minimize the effects of the SSO
• Provide containment and proper clean-up of the SSO
• Investigate SSOs
• Notify stake-holders of a SSO.
5.2.2 Root Cause Failure Analysis. All SSOs are required to be investigated to determine
the root cause of the overflow. A Root Cause Failure Analysis Form can be found
in the ORP SOP (Appendix D) and in Appendix E..
5.3 Overflow Structures and Monitored Sites
5.3.1 There are fourteen gravity sewer overflow points in the Village system as identified
in Table 2-3 Sanitary Sewer Overflow and Monitored Sites.
5.3.2 There are two sites that are monitored for potential basement backups as identified
in Table 2-3.
5.3.3 As part of the implementation of the CMOM Plan, an Standard Operating Procedure
(SOP) was developed to address these overflow points. See Wet Weather SOP in
Appendix F.
5.3.4 In the event of an overflow or an emergency (blocked sewer, collapse, backup, etc.)
SOPs should be followed.
5.4 Notification
In the event of an overflow, the Village needs to submit notification to various stakeholders.
See emergency contact list in the Appendix D, Table D-2. These are as follows:
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SECTION 5 –OVERFLOW RESPONSE PLAN
1. Notify Village Manager

2. Verbal or email notification to the DNR within 24 hours notification that an overflow
occurred
3. Written overflow report to the DNR within five (5) days. The form can be found on the
DNR website and is included in the Appendix E.
4. Email to the Water Supply Utilities that are impacted by the overflow. These
notifications are found in the ORP.
5.5 Weather Forecast
The Village also uses weather forecast to predict wet weather events and melting snow events
which can assist in predicating high flows in the system and allows Village staff to be prepared
to address potential problems in the collection system.
• Channel 4 – NBC - TMJ 4 – news station http://weather.todaystmj4.com/

• Channel 6 –FOX - www.fox6now.com
• Channel 12 – ABC – www.wisn.com
• http://www.wunderground.com/cgi-bin/findweather/getForecast/
• www.noaa.gov
• www.nws.noaa.gov
• www.weather.com
• District http://v3.mmsd.com/StormUpdate.aspx/
5.6 Root Cause Failure Analysis
5.6.1 All overflows are investigated to determine what caused the overflow.
5.6.2 Other problems in the system, such as blockages or basement backups, are also
investigated to determine the cause.
5.6.3 See Root Cause Analysis Form in Appendix E.
5.7 References
5.7.1 See Overflow Response Plan SOP in Appendix D for more details.
5.7.2 Wet Weather SOP in Appendix F
5.7.3 Root Cause Failure Analysis Form in Appendix E
t h
SECTION 6 – CONDITION ASSESSMENT PROGRAM
A Condition Assessment Program involves documentation and inspection of the collection

system to assess the condition of the infrastructure. The information gathered during the
assessment is used to plan and budget for repair, rehabilitation and replacement of the assets.
Also from these assessments, recommendations for additional inspection and cleaning are
made. There are several key elements that are part of the Condition Assessment Program:
6.2 Condition Assessment Key Elements
6.2.1 The tools listed in Section 3 - Operation and Maintenance Plans will be used for
condition assessment. See Section 3 for more details. These tools include but are
not limited to inspection, cleaning, smoke testing, dye water flooding and root
control.
6.2.2 Document inspections from sewers and manholes.
6.2.3 Document cleaning results.
6.2.4 Data from the inspections and cleaning is reviewed and evaluated by an
experienced person. The condition of the sewers and manholes is assessed and
rated via the assessment code. The assessment code used is the Pipeline
Assessment and Certification Program (PACP) as provided through the National
Association of Sewer Service Companies (NASSCO). Sewer inspections are
performed by a consultant.
6.2.5 Based on the condition assessment rating, recommendations are made on an on-
going basis to repair, rehabilitate, and replace to properly maintain the asset
6.2.6 Analysis of system performance, maintenance history, age materials and structural
risk analysis is also used to help prioritize recommendations.
6.3 Condition Assessment Recommendations
6.3.1 Recommendations to repair, replace, and rehabilitate the assets are based on the
results of the condition assessment.
6.3.2 Depending upon the severity of the condition, the recommendations shall be
performed by staff or contracted out to a consulting firm.
6.3.3 Solutions for repair and rehabilitation will depend up on the condition of the asset
and using the appropriate technology for the problem.
6.3.4 Recommendations will be used for O&M budgets and CIP.
t h
SECTION 7 COMMUNICATIONS
The Village of Whitefish Bay communicates with the DNR, District, the Village Board and their
customers on a regular basis. The Village is governed by a Village President and 6 Village
Trustees as outlined in the Village Organization Chart in Figure 2-1.
7.2 Methods of Communication
The Village Board meets on a monthly basis to decide administrative issues related to finance,
personnel, operations, SSO reduction and elimination, sanitary sewer system improvements
and other Village business is discussed. Any SSO events or other capacity issues are
presented and discussed at the Board meetings.
Currently, the Village has a web-site and quarterly newsletter to update their customers.
7.3 CMOM Communication
Topics of discussion related to the CMOM Plan are:
1. Financial Impact to the Village. Is the budget adequate to support initiatives including
but not limited to: Capital improvements, operation and maintenance activities,
personnel and equipment.
2. Problem areas in the system.
3. Sanitary Sewer Overflows.
4. Communication to stakeholders.
5. Meeting the CMOM Goals
6. Reducing I/I in the system in the most cost-effective way.
7.4 Reporting Methods
As part of the Communications Plan, the Village has reporting requirements to other entities as
listed in Table 8-1 and as outlined in the Overflow Response Plan (Appendix D). In addition,
an annual Communications Plan as required by the District will be submitted including the
component items listed above and in the District rules. The plan will include an update on
meeting the performance measures.
7.5 References
1. Table 8-1 Audit and Reporting Schedule

2. Overflow Response Plan (ORP) Appendix D.
t h
SECTION 8 CMOM AUDIT PLAN
A CMOM audit is necessary to ensure that the Plan is properly implemented goals and
objectives are met and performances measures are reviewed, evaluated, an updated on a
regular basis.
The CMOM Plan provides the framework and documentation to implement the programs that
the Village is currently doing. This Plan is meant to be a working document and will be
updated as needed.
As part of the Audit the following will be done:
1. Audit and review the CMOM Plan

2. Monitor the Plan
3. Provide recommendations
4. Update the CMOM Plan
8.2 Audit and Review the Plan
8.2.1 Audits shall be done every five years in accordance with the Stipulation. See
Table 8-1 for reporting requirements.
8.2.2 Review the Plan for the following:
8.2.2.1 Goals are applicable to the Village
8.2.2.2 Goals and strategies are applicable and meet the Stipulation, DNR and District
requirements.
8.2.2.3 Program elements are applicable and relevant
8.2.2.4 Performance measures are being met. See Table 2-4 for performance
measures.
8.2.2.5 Budget is adequate to meet the recommendations from the various CMOM
components.
8.3 Monitor the Plan
8.3.1 Monitor the implementation and measure the effectiveness of the program through
performance measures.
8.3.2 Annually, review goals and performance measures to measure the program
effectiveness.
t h
8.3.3 Submit reports as required by DNR and the District.
8.4 Provide Recommendations
8.4.1 Provide recommendations to revise the performance measures.
8.4.2 Provide recommendation to update the Plan.
8.5 Update the CMOM Plan
8.5.1 Update the CMOM Plan based on the audit, feedback from employees and
recommendations. See Tables 8-2 and 8-3 to update the CMOM Plan and Table
8-4 for the CMOM Plan Distribution List.
EXHIBIT 8-1 AUDIT & REPORTING SCHEDULE
DESCRIPTION 2009 2010 2011 2012 2013 2014

AUDIT
Develop goals and performance measures X X X X X X
Review actual goals and performance X X X X X X
measures
Review and update budget and rates X X X X X X
CMOM Audit X
REPORTING SCHEDULE
District – I/I Report March 1st X X X X X X
District – Chapter 13 Storm April 30th X X X X X X
District – Communications Annual Report X X X X X X
DNR – CMAR Report June 30th X X X X X X

WNDR – NR 216 Report – March 31st X X X X X X
MS4 Permit
Clean water funding reporting requirements
as necessary.
Sanitary Sewer Overflow Notification – See
Overflow Response Plan in Appendix D.
t h
Table 8-2
CMOM Plan Update Documentation Table
Update Update Update Update Update Manual Update Comments
No. Manual No. 1 Manual No. 2 Manual No. 3 No. 4 & 5 Manual No. 6
Ver 2 11/30/09 11/30/09 11/30/09 11/30/09 11/30/09
Final Submitted 2/25/2010 –
Ver 3 2/25/2010 2/25/2010 2/25/2010 2/25/2010 2/25/2010
Approved by District 4/8/2010
February 25th, 2010 Page 31

Table 8-3
Audit and Plan Update Documentation Table
Audit Completed By: Audit CMOM Plan Updated By: Plan Updated Approved By: Date Update
Date: Date Approved Number
1
February 25th, 2010 Page 32

TABLE 8-4
CMOM PLAN DISTRIBUTION LIST
MANUAL NAME ENTITY DATE
NO.
No. 1 Daniel Naze Village of Whitefish Bay 6/29/2009
No. 2 Aaron Jahncke Village of Whitefish Bay 6/29/2009
No. 3 & 4 Debra Jensen District 260 West Seeboth, 6/29/2009

Milwaukee WI, 53204
No. 5 Joan B. Hawley Superior Engineering, 6/29/2009

S75W13139 Oxford Court,
Muskego, WI 53150
February 25, 2010 Page 33

Appendix A
Appendix B
MMSD CMOM Program Appendix 1-1
Stipulation Requirements of the District’s CMOM Program
Below is the portion of the text (from pages 7, 8, and 9) of the Stipulation entered into
between the Milwaukee Metropolitan Sewerage District and the State of Wisconsin in
2002 that describes the District CMOM Program requirements.
“CAPACITY, MANAGEMENT, OPERATION

AND MAINTENANCE (CMOM) PROGRAM
6. Combined sewer overflows and sanitary sewer overflows present important

concerns for public health and the environment. The State, through the Department of
Natural Resources, acknowledges that the District has accomplished significant
reductions in the number of overflows experienced with the District’s Metropolitan
Interceptor Sewer System through implementation of the Water Pollution Abatement
Program (WPAP.)
7. While sanitary sewer overflows in the District’s system have been significantly
reduced, there are still sanitary sewer overflows within the District’s and its satellite
municipalities’ sanitary sewer systems. To continue the District’s program to reduce
with the goal of eliminating all non-permitted sanitary sewer overflows, the District shall
implement the regional Capacity, Management, Operation and Maintenance (CMOM)
program. The regional CMOM shall be comprised of four integrated components:
A. Management Plan. A plan that outlines the goals of the CMOM, the
organizational structure to manage it, the legal authority to control infiltration and inflow
(I/I), design criteria, benchmarking data, and performance measures to attain the goals. A
significant effort associated with the Management Plan shall be the development of an
asset management (AM) program that provides for both programmed maintenance and
tracking of the asset condition to enable early recognition of expansions or major
rehabilitation necessary to avoid capacity limitations.
B. Overflow Response Plan. An overflow response plan that identifies
measures to protect public health and the environment. This plan will outline the public
notification, permit reporting, measuring and monitoring steps to be taken during an
overflow event.
C. System Evaluation and Capacity Assurance Plan. A Plan for system
evaluation and capacity assurance for peak flow conditions. This plan shall identify
necessary capital improvements to meet the projected flows and an implementation plan
that describes timing and responsibilities for implementing each capital project.
D. Communication and Program Audit Plan. On a regular basis the District
shall report to the Department on the implementation and performance of the CMOM
program. The communication and program audit plan shall allow for public input during
the development and implementation of the CMOM.
E. The approach to be used by the District to initiate and maintain the
CMOM program shall include the following steps:
1) Retention of a consultant by no later than December 31, 2002, to
provide program oversight and guidance.
2) Review of existing operations and existing management and capital
improvement plans.
3) Development of an action plan to assess the required changes to
existing plans and to develop a critical plan approach to a CMOM program
Page 1 of 2 June 2007

Stipulation Requirements of the District’s CMOM Program
4) Concurrent with previous steps, review of existing information on
asset management, including field verification as required, and software development to
provide a simplified data base to manage the capital assets of the District.
5) Open and maintain a CMOM dialog with the 28 satellite
municipalities through the Technical Advisory Team with the goal of assisting the
satellite municipalities with developing individual CMOM programs. The District shall
develop prospective measures for the satellite systems that will reflect the requirements
of the District’s CMOM program.
6) This entire CMOM initiative will be coordinated with the ongoing
facilities planning and shall be completed by no later than June 30, 2007 and documented
in the 2020 Facilities Plan to ensure future oversight of this program.

Withdrawn SSO Rule
Below is the draft SSO Rule language (USEPA proposed rule § 122.42 paragraphs (e),
(f), and (g)) that was proposed in 2001 and subsequently withdrawn.
“(e) Municipal Sanitary Sewer System – Capacity, Management, Operation and

Maintenance Programs. (1) General Standards. You, the permittee, must:
(i) Properly manage, operate, and maintain, at all times, all parts of the
collection system that you own or over which you have operational
control;
(ii) Provide adequate capacity to convey base flows and peak flows for all
parts of the collection system you own or over which you have operational
control;
(iii) Take all feasible steps to stop, and mitigate the impact of, sanitary sewer
overflows in portions of the collection system you own or over which you
have operational control;
(iv) Provide notification to parties with a reasonable potential for exposure to
pollutants associated with the overflow event; and
(v) Develop a written summary of your CMOM Program and make it, and the
audit under paragraph (e) (2) (ix) of this section, available to any member
of the public upon request.
(2) Components of CMOM Program. You must develop and implement a capacity,
management, operation and maintenance (CMOM) program to comply with
paragraph (e)(1) of this section. If you believe that any element of this section is
not appropriate or applicable for your CMOM program, you program does not
need to address it, but your written summary must explain why that element is not
applicable. The Director will consider the quality of the CMOM program, its
implementation and effectiveness in any relevant enforcement action, including
but not limited to any enforcement action for violation of the prohibition of any
municipal sanitary sewer system discharges described at paragraph (f) of this
section. The program must include the following components, with the exception
of non-applicable components as discussed above:
(i) Goals. You must specifically identify the major goals of your CMOM
program, consistent with the general standards identified above.
(ii) Organization. You must identify:
(A) Administrative and maintenance positions responsible for
implementing measures in your CMOM program, including lines of
authority by organization chart or similar document; and
(B) The chain of communication for reporting SSOs under paragraph (g)
of this section from receipt of a complaint or other information to the
person responsible for reporting
(iii) Legal Authority. You must include legal authority, through sewer use
ordinances, service agreements or other legally binding documents, to:
(A) Control infiltration and connections from inflow sources;

Withdrawn SSO Rule
(B) Require that sewers and connections be properly designed and
constructed;
(C) Ensure proper installation, testing, and inspection of new and
rehabilitated sewers (such as new or rehabilitated collector sewers
and new or rehabilitated service laterals);
(D) Address flows from municipal satellite collection system; and
(E) Implement the general and specific prohibitions of the national
pretreatment program that you are subject to under 40 CFR 403.5.
(iv) Measures and Activities. Your CMOM program must address the
following elements that are appropriate and applicable to your system and
identify the person or position in your organization responsible for each
element:
(A) Provide adequate maintenance facilities and equipment;
(B) Maintenance of a map of the collection system;
(C) Management of information and use of timely, relevant information
to establish and prioritize appropriate CMOM activities (such as the
immediate elimination of dry weather overflows or overflows into
sensitive waters such as public drinking water supplies and their
source waters, swimming beaches and waters where swimming
occurs, shellfish beds, designated Outstanding National Resource
Waters, National Marine Sanctuaries, waters within Federal, State,
or local parks, and water containing threatened or endangered
species or their habitat), and identify and illustrate trends in
overflows, such as frequency and volume;
(D) Routine preventive operation and maintenance activities;
(E) A program to assess the current capacity of the collection system and
treatment facilities which you own or over which you have
operational control;
(F) Identification and prioritization of structural deficiencies and
identification and implementation of short-term and long-term
rehabilitation actions to address each deficiency;
(G) Appropriate training on a regular basis; and
(H) Equipment and replacement parts inventories including identification
of critical replacement parts.
(v) Design and Performance Provisions. You must establish:
(A) Requirements and standards for the installation of new sewers,
pumps and other appurtenances; and rehabilitation and repair
projects; and
(B) Procedures and specifications for inspecting and testing the
installation of new sewers, pumps and other appurtenances and for
rehabilitation and repair projects.
(vi) Monitoring, Measurement, and Program Modifications. You must:
(A) Monitor the implementation and, where appropriate, measure the
effectiveness of each element of your CMOM program; and

Withdrawn SSO Rule
(B) Update program elements as appropriate based on monitoring or
performance evaluations; and
(C) Modify the summary of your CMOM program as appropriate to keep
it updated and accurate.
(vii) Overflow Emergency Response Plan. You must develop and implement an
overflow emergency response plan that identifies measures to protect
public health and the environment. The plan must include mechanisms to:
(A) Ensure that you are made aware of all overflows, to the greatest
extent possible;
(B) Ensure that overflows (including those that do not discharge to
waters of the U.S.) are appropriately responded to, including
ensuring that reports of overflows are immediately dispatched to
appropriate personnel for investigation and appropriate response;
(C) Ensure appropriate immediate notification to the public, health
agencies, other impacted entities (e.g. water suppliers) and the
NPDES authority. The CMOM program should identify the public
health and other officials who will receive immediate notification;
(D) Ensure that appropriate personnel are aware of and follow the plan
and are appropriately trained; and
(E) Provide emergency operations.
(viii) System Evaluation and Capacity Assurance Plan. You must prepare and
implement a plan for system evaluation and capacity assurance if peak
flow conditions are contributing to an SSO discharge or to noncompliance
at a treatment plant unless you have already taken steps to correct the
hydraulic deficiency or the discharge meets the criteria of paragraph (f) (2)
[Discharges Caused by Severe Natural Conditions] of this section. At a
minimum the plan must include:
(A) Evaluation. Steps to evaluate those portions of the collection system
which you own or over which you have operational control which
are experiencing or contributing to an SSO discharge caused by
hydraulic deficiency or to noncompliance at a treatment plant. The
evaluation must provide estimates of peak flows (including flows
from SSOs that escape from the system) associated with conditions
similar to those causing overflow events, provide estimates of the
capacity of key system components, identify hydraulic deficiencies
(including components of the system with limiting capacity) and
identify the major sources that contribute to the peak flows
associated with overflow events.
(B) Capacity Enhancement Measures. Establish short- and long-term
actions to address each hydraulic deficiency including prioritization,
alternatives analysis, and a schedule.
(C) Plan Updates. The plan must be updated to describe any significant
change in proposed actions and/or implementation schedule. The
plan must also be updated to reflect available information on the
performance of measures that have been implemented.

Withdrawn SSO Rule
(ix) CMOM Program Audits. – As part of the NPDES permit application, you
must conduct an audit, appropriate to the size of the system and the
number of overflows, and submit a report of such audit, evaluating your
CMOM and its compliance with this subsection, including its deficiencies
and steps to respond to them.
(3) Communications. – The permittee should communicate on a regular basis with
interested parties on the implementation and performance of its CMOM program.
The communication system should allow interested parties to provide input to the
permittee as the CMOM program is developed and implemented.
(4) Small Collection Systems. – The Director of the NPDES authority may make the
following modifications when establishing the CMOM program permit condition
for:
(i) Municipal sanitary sewer collection systems with an average daily flow of
1.0 million gallons per day or less, the CMOM permit provision may omit
the following paragraphs: (e) (2) (iii)(A) through (E); (e) (2) (iv) (A), and
(e) (2) (iv) (C) through (H) of this section. In addition, the requirements in
paragraph (e) (2) (v) of this section may be modified for municipalities
that are not expected to have significant new installations of sewers,
pumps and other appurtenances.
(ii) Municipal sanitary sewer collection systems with an average daily flow of
2.5 million gallons per day or less, the requirement to develop a written
summary of the permittee’s CMOM plan ((e) (1) (v)) and the requirement
to conduct an audit and prepare a written audit report ((e) (2) (ix)) may be
omitted unless triggered by the occurrence of an SSO that discharges to
waters of the United States from the permittee’s collection system during
the term of the permit.
(f) Municipal Sanitary Sewer Systems – Prohibition of Discharges. (1) General

Prohibition. Municipal sanitary sewer system discharges to waters of the United
States that occur prior to a publicly owned treatment works (POTW) treatment
facility are prohibited. The term POTW treatment facility means an apparatus or
device designed to treat flows to comply with effluent limitations based on
secondary treatment regulations or more stringent water quality-based
requirements. Neither the bypass or the upset provisions at § (m) and (n),
respectively, apply to these discharges.
(2) Discharges Caused by Severe Natural Conditions. – The Director may take
enforcement action against the permittee for a prohibited municipal sanitary sewer
system discharge caused by natural conditions unless the permittee demonstrates
through properly signed, contemporaneous operating logs, or other relevant
evidence that:
(i) The discharge was caused by severe natural conditions (such as
hurricanes, tornados, widespread flooding, earthquakes, tsunamis, and
other similar natural conditions);
(ii) There were no feasible alternatives to the discharge, such as the use of
auxiliary treatment facilities, retention of untreated wastewater, reduction
of inflow and infiltration, use of adequate backup equipment, or an

Withdrawn SSO Rule
increase in the capacity of the system. This provision is not satisfied if, in
the exercise of reasonable engineering judgment, the permittee should
have installed auxiliary or additional collection system components,
wastewater retention or treatment facilities, adequate back-up equipment
or should have reduced inflow and infiltration; and
(iii) The permittee submitted a claim to the Director within 10 days of the date
of the discharge that the discharge meets the conditions of this provision.
(3) Discharges Caused by Other Factors. – For discharges prohibited by paragraph (f)
(1) of this section, other than those covered under paragraph (f) (2) of this section,
the permittee may establish an affirmative defense to an action brought for
noncompliance with technology based permit effluent limitations if the permittee
demonstrates through properly signed, contemporaneous operating logs, or other
relevant evidence that:
(i) The permittee can identify the cause of the discharge event;
(ii) The discharge was exceptional, unintentional, temporary and caused by
factors beyond the reasonable control of the permittee;
(iii) The discharge could not have been prevented by the exercise of reasonable
control, such as proper management, operation and maintenance; adequate
treatment facilities or collection system facilities or components (e.g.,
adequately enlarging treatment or collection facilities to accommodate
growth or adequately controlling and preventing infiltration and inflow);
preventive maintenance; or installation of adequate backup equipment;
(iv) The permittee submitted a claim to the Director within 10 days of the date
of the discharge that the discharge meets the conditions of this provision;
and
(v) The permittee took all reasonable steps to stop, and mitigate the impact of,
the discharge as soon as possible.
(4) Burden of proof. In any enforcement proceeding, the permittee has the burden of
proof to establish that the criteria in this section have been met.
(g) Municipal Sanitary Sewer Systems – Reporting, Public Notification and

Recordkeeping. This condition establishes recordkeeping, reporting and public
notification requirements for your municipal sanitary sewer system and sanitary
sewer overflows from your municipal sanitary sewer system. You do not have to
report sanitary sewer overflows under § 122.41 (l) if the sanitary sewer overflows
are reported under this section. (1) Definition of Sanitary Sewer Overflow. A
sanitary sewer overflow (SSO) is an overflow, spill, release, or diversion of
wastewater from a sanitary sewer system. SSOs do not include combined sewer
overflows (CSOs) or other discharges from the combined portions of a combined
sewer system. SSOs include:
(i) Overflows or releases of wastewater that reach waters of the United
States;
(ii) Overflows or releases of wastewater that do not reach waters of the United
States; and
(iii) Wastewater backups into buildings that are caused by blockages or flow
conditions in a sanitary sewer other than a building lateral. Wastewater

Withdrawn SSO Rule
backups into buildings caused by a blockage or other malfunction of a
building lateral that is privately owned is not an SSO.
(2) Immediate Notifications and Follow-Up Reports. You must provide the
following additional reports for sanitary sewer overflows (including overflows
that do not reach waters of the United States) that may imminently and
substantially endanger human health:
(i) You must immediately notify the public, health agencies and other
affected entities (e.g. public water systems) of overflows that may
imminently and substantially endanger human health. The notification
should be in accordance with your CMOM overflow emergency response
plan (see paragraph (e) (2) (vii) of this section);
(ii) You must provide to the NPDES authority either an oral or electronic
report as soon as practicable within 24 hours of the time you become
aware of the overflow. The report must identify the location, estimated
volume and receiving water, if any, of the overflow; and
(iii) You must provide to the NPDES authority within 5 days of the time you
become aware of the overflow a written report that contains:
(A) The location of the overflow;
(B) The receiving water (if there is one);
(C) An estimate of the volume of the overflow;
(D) A description of the sewer system component from which the release
occurred (e.g., manhole, constructed overflow pipe, crack in pipe);
(E) The estimated date and time when the overflow began and stopped
or will be stopped;
(F) The cause or suspected cause of the overflow;
(G) Steps taken or planned to reduce, eliminate, and prevent
reoccurrence of the overflow and a schedule of major milestones for
those steps; and
(H) Steps taken or planned to mitigate the impact(s) of the overflow and
a schedule of major milestones for those steps.
(iv) The Director may waive the written report required by paragraph (g) (2)
(iii) of this section 122.42 (g) (2) (iii) on a case-by-case basis.
(3) Discharge Monitoring Reports. You must report sanitary sewer overflows that
discharge to waters of the United States on the discharge monitoring report
(DMR), including the following information:
(i) The total number of system overflows that discharge to waters of the
United States that occurred during the reporting period;
(ii) The number of locations at which sanitary sewer overflows that discharge
to waters of the United States occurred during the reporting period that
resulted from flows exceeding the capacity of the collection system;
(iii) The number of sanitary sewer overflows that discharge to waters of the
United States that are unrelated to the capacity of the collection system
that occurred during the reporting period; and
(iv) The number of locations at which sanitary sewer overflows that discharge
to waters of the United States that occurred during the reporting period
that are unrelated to the capacity of the collection system.

Withdrawn SSO Rule
(4) Annual Report.
(i) You must prepare an annual report of all overflows in the sewer system,
including overflows that do not discharge to waters of the United States.
The annual report must include the date, the location of the overflow, any
potentially affected receiving water, and the estimated volume of the
overflow. The annual report may summarize information regarding
overflows of less than approximately 1,000 gallons. You must provide the
report to the Director and provide adequate notice to the public of the
availability of the report.
(ii) System serving fewer than 10,000 people are not required to prepare an
annual report if all DMRs for the preceding 12 months show no discharge
to waters of the United States from overflows.
(5) Recordkeeping. You, the permittee, must maintain a record of the following
information for a period of at least 3 years from the date of the overflow or other
recorded event:
(i) For each sanitary sewer overflow, including overflows that did not
discharge to waters of the United States, which occurred in your collection
system or as a result of conditions in a portion of the collection system
which you own or over which you have operational control:
(A) The location of the overflow and the receiving water if any;
(B) An estimate of the volume of the overflow;
(C) A description of the sewer system component from which the release
occurred (e.g., manhole, constructed overflow pipe, crack in pipe);
(D) The estimated date and time when the overflow began and when it
stopped;
(E) The cause or suspected cause of the overflow; and
(F) Steps that have been and will be taken to prevent the overflow from
recurring and a schedule for those steps.
(ii) Work orders which are associated with investigation of system problems
related to sanitary sewer overflows;
(iii) A list and description of complaints from customers or others; and
(iv) Documentation of performance and implementation measures.
(6) Additional Public Notification. You must notify the public of overflows,
including overflows that do not discharge to waters of the United States, in areas
where an overflow has a potential to affect human health. The criteria for
notification should be developed in consultation with potentially affected entities.
The notification should be in accordance with your CMOM overflow emergency
response plan (see paragraph (e) (2) (vii) of this section.)”

Appendix C
CMOM PLAN – APPENDIX C – District Copy Only –Municipalities received a copy of the
complete Strategic Plan to include in their Manuals. For purpose of this document only the
cover sheet has been included.
CMOM Strategic Plan
Village of Whitefish Bay
1/7/2008
FINAL
EXECUTIVE SUMMARY ................................................................................................................................................1

Introduction and Background .........................................................................................................................................1
CMOM Program Development Process .........................................................................................................................1
Major CMOM Program Implementation Tasks .................................................................................................................3
Chapter 1 - Strategy Introduction .......................................................................................................................................6
1.0 Program Background ..........................................................................................................................................6
1.1.0. CMOM Program Development Process .........................................................................................................8
1.2.0. Strategy Outline...................................................................................................................................................9
1.3.0 Potential Regulatory Expectations.......................................................................................................................10
1.3.1. MMSD Rules......................................................................................................................................................10
1.3.2. Satellite Stipulation Requirements .....................................................................................................................10
1.4.0. CMOM Tactics Which the Village of Whitefish Bay Is Already Practicing......................................................12
1.4.1 Organizational Structure, Including Administrative and Maintenance Positions .....................................12
1.4.2 Legal Authority to Control I/I and Construction Standards......................................................................12
1.4.3 Provide Adequate Maintenance Facilities and Information Management ................................................12
1.4.4 Program to Assess the Current Capacity of the Collection.......................................................................13
1.4.5 Identification of Structural Deficiencies and Implementation of Rehabilitation Actions .........................13
1.4.6 Design Requirements and Standards for the Installation of New Sewers.................................................13
1.4.7 Monitor, Measure and Update Program Elements as Appropriate ...........................................................13
1.4.8 Provide a Detailed SSO Emergency Response Plan .................................................................................14
1.4.9 Provide for Public Notification of SSO Occurrences ...............................................................................14
1.4.10 Provide a System Evaluation and Capacity Assurance Plan to Address SSOs.........................................14
1.4.11 Conduct a CMOM Program Audit as Part of the Permit Application ......................................................14
Chapter 2 - Management Plan Strategy ............................................................................................................................15
2.1.0. CMOM Program...........................................................................................................................................15
2.1.1. CMOM Program Mission Statement ............................................................................................................16
2.1.2. CMOM Program Goals ................................................................................................................................16
2.1.3. CMOM Program Objectives.........................................................................................................................17
Chapter 3 - Overflow Response Plan Strategy .................................................................................................................25
Chapter 4 - System Evaluation and Capacity Assurance Plan Strategy ...........................................................................40
Chapter 5 - CMOM Program Communication Plan Strategy ...........................................................................................54
Chapter 6 – CMOM Program Audit Plan Strategy...........................................................................................................57
Chapter 7 - CMOM Program Implementation Strategy ...................................................................................................60
7.1.0 Summary of Implementation Activities........................................................................................................61
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7.2.0. Documents to Be Prepared As Part of CMOM Program Implementation ....................................................62
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EXECUTIVE SUMMARY
Introduction and Background

In May 2002, the Milwaukee Metropolitan Sewerage District (MMSD) entered into a Stipulation
(MMSD Stipulation) with the Wisconsin Department of Natural Resources (WDNR). Among other
items, the Stipulation requires MMSD to implement a Capacity assurance, Management,
Operations and Maintenance (CMOM) Program. The MMSD Stipulation also required MMSD to
amend its rules to by June 30, 2007 to require CMOM Programs for all MMSD satellite
municipalities.
In December 2005, the Village of Whitefish Bay, along with other MMSD satellites, entered into a
Stipulation with the WDNR (Satellite Stipulation), that committed the Village to develop and
implement a CMOM Program.
The CMOM concept is set forth in a U. S. Environmental Protection Agency (USEPA) draft rule
that addresses sanitary sewer overflow (SSO) control. A provision of the draft document is a
requirement for a comprehensive collection system program that includes four key components, 1)
Capacity assurance, 2) Management, 3) Operation, and 4) Maintenance; hence the acronym
“CMOM.” The goal of CMOM is to clearly define proper operation and maintenance of the
collection system and a system owner’s duty to mitigate SSOs. The USEPA CMOM draft would
require a collection system owner to:
• Properly manage, operate and maintain, at all times, all parts of the collection system that it
owns or over which it has operational control.
• Provide adequate capacity to convey base flows and peak flows for all parts of the
collection system it owns or over which it has operational control.
• Take all feasible steps to stop, and mitigate the impact of, sanitary sewer overflows in
portions of the collection system it owns or over which it has operational control.
• Provide notification to parties with a reasonable potential for exposure to pollutants
associated with the overflow event.
• Develop a written summary of the CMOM program and make it, and the audit under section
(e)(2)(ix), available to any member of the public upon request.
The WDNR is developing its CMOM regulations which closely follow the federal version. It is
anticipated that the WDNR permit staff will have the authority to include CMOM provisions in
individual Wisconsin Pollution Discharge Elimination System (WPDES) permits and the general
collection system WPDES permits. Once this occurs, the Village would be required to follow
WDNR CMOM permit requirements.
CMOM Program Development Process

The CMOM Program developed for Village followed a two step process. First, a CMOM
Readiness Review of the Village was performed. Second, this CMOM Strategic Plan was
developed.
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For the CMOM Readiness Review, a consulting team led by Superior Engineering conducted a
workshop with managers from the Village to familiarize them with the Readiness Review process.
Afterward, the team collected information for the Readiness Review from documents, staff
interviews, and field observations. The Readiness Review identified a number of required practices
and documents were already in place, some areas needed to be improved to meet the CMOM Plan
requirements. . After evaluating its current status in each practice area, the Village selected a goal
and a priority for progressing in each area.
The following list summarizes the highest priorities Village identified for developing its CMOM
program:
1. Identify and reduce infiltration/inflow

2. Review and enhance the existing in-house cleaning and inspection program
3. Standardize O&M Procedures
Following the Readiness Review, the same consulting team guided Village staff through a process
to develop the CMOM Strategic Plan. The first task in this process involved the Village reviewing
a CMOM Program Mission Statement followed by program goals and objectives. The Village staff
is developing a mission statement to guide development of the strategy which will be required to
be approved by the Village Board. This will be one of the first steps in the development of the
CMOM Plan.
Summary of Findings of Readiness Review

The Village of Whitefish Bay has completed most of the tasks that are required to comply with a
CMOM Plan. To complete the CMOM Plan, the Village will need to compile all the existing
documents and programs and incorporate them into one document. There will need to be several
minor updates to the existing programs such as the Overflow Response Plan (ORP) to comply with
all the CMOM requirements. There are extensive capital improvement projects currently being
implemented based on the extensive inspection work that has been completed. Operations and
Maintenance activities has been undertaken, and additional documentation maybe required to meet
include all O&M work practices and responsibilities. For more details, refer to the Readiness
Review Report submitted to the Village in January 2006.
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Major CMOM Program Implementation Tasks

The Village of Whitefish Bay has the majority of the CMOM Plan elements in place and compiling
this information under one document will provide the framework for the CMOM Plan.
Management Programs
1. Policies and Procedures. The Village has the majority of the CMOM programs in place.
There are some documented policies and procedures and the Village is working on finalizing
these policies and procedures.
2. Fats Oil and Grease (FOG). This program currently is not part of the Public Works
department. Review of this program should be completed and a FOG program developed
including annual inspections. Coordination of this program between the health department and
the public works should be implemented. Inspections need to be documented and public
education enhanced to educate Village departments regarding the impact of FOG on the sewer
system.
3. Customer Service and Complaint Program. The existing program is in place. The program
needs to be reviewed and updated as necessary. The existing program reviews the complaints
and addresses the solution via an inspection, cleaning or CIP project.
4. Legal Programs. There are many legal programs that are necessary to ensure that the Village
will be able to legally enforce their program and eliminate clear water from the system.
a. Review and update the Sewer Use Ordinance (SUO).
b. FOG. Review program and determine if any revisions to ordinances will be required.
c. The Village has recently requiring that property owners replace laterals if the sewer is
being replaced. This program has just been implemented.
5. Training. Most of the training is done on the job. Specific training appropriate to the
equipment should be developed. The Village currently has a cleaning truck and TV unit.
Annual inspection of the cleaning truck and cleaning pressures should be performed by the
manufacturer.
6. Capital Improvements Plan. The Village has completed many capital improvements over the
past years and has a comprehensive CIP in place.
7. Safety Program – Review and enhance and necessary. Program is well documented in most
parts and reviewed on an annual basis. This level of effort should be continued with this level
of effort and enhanced by scheduling safety tail gate meetings.
Operation and Maintenance Programs

1. Inspection Program. The existing sewer and manhole inspection programs are in place and
documented. A 10 year CIP has been implemented using the information from these
inspections. The Village should continue this comprehensive approach. Other areas to review
and potentially update are:
a. Review and update the sewer and manhole inspection programs including condition
assessment guidelines.
b. Review existing sewer and manhole inspection schedules and modify as necessary based
on the results of the inspections.
c. Review existing inspection forms for manholes and sewers and update as necessary.
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d. Review and update the inspection program for maintenance of right of ways and
easements.
e. Continue to use the condition assessment information to provide recommendations for
repairs, rehabilitation and replacement.
2. Cleaning Program. The current program is in place and half of the system is cleaned every
other year and the schedule has recently been changed to cleaning one-third the sewers each
year and the work is documented. The documentation of this program should be reviewed to
ensure that the data is being used effectively.
a. Review existing cleaning form and enhance as necessary.
b. Review any frequently visited areas to determine why these areas need to be cleaned
more frequently.
c. Develop procedures to verify if the sewers have been cleaned properly via inspection
spot checks.
d. Develop guidelines to determine cleaning cycle for each basin and review on an annual
basis. The Village is currently doing this informally, but needs to be documented.
System Evaluation and Capacity Assurance Plan (SECAP).
1. System Evaluation and Capacity Assurance Plan (SECAP). The system flows have been
previously modeled. Based on these results, recommendations for sewer and manhole
rehabilitation projects were incorporated into the CIP. The Village has been implementing
these projects. Use the template provided by MMSD to provide guidance for the plan if a
SECAP is required.
Overflow Response Plan.
1. Overflow Response Plan. The Village has a written procedure to address overflows. This
procedure should be reviewed and enhanced as necessary to address overflows and other wet
weather responses. These procedures are documented and mock drills are performed. The
Village can use the template provided by MMSD as a guideline for this plan to expand as
necessary.
The MMSD Stipulation and amended rules require satellite municipality CMOM adoption within
two years of MMSD initiating its CMOM Program. MMSD will complete all activities essential to
CMOM Implementation, including CMOM Rule adoption, by June 30, 2007, the Village must
implement its CMOM Program by June 30, 2009. At a minimum, the Village will need to develop
the following documents by that date:
1. Management Plan
2. Overflow Response Plan
3. Communications Plan
4. Audit Plan
5. Annual CMOM Report
6. Operation and Maintenance Plan including procedures for the sewer collection system
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The above documents do not represent completion of the Village CMOM Program. As CMOM is a
cyclical process, the Village will regularly update these documents as necessary so they accurately
reflect how the system is being managed, operated, and maintained. In addition, the Village will
work to make the improvements identified in the Readiness Review according to the priorities
established during that process. The 5-Year CMOM Audit will serve to evaluate the progress that
has been made in these areas.
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Chapter 1 - Strategy Introduction

The Village of Whitefish Bay has initiated a Capacity assurance, Management, Operations and
Maintenance (CMOM) program in order to determine a strategic direction for developing and
implementing best business practices in the areas of capacity management, organizational
management, and operations and maintenance (O&M). These desired best business practices are
fundamental to delivering wastewater collection services. Other practices that would address larger
Village organizational issues (e.g., personnel management and asset management) are not included
in this project. The Village may consider developing a process or procedure to address these other
organizational issues. Section 1.3 summarizes specific activities the Village currently practices
which fulfill the likely CMOM Program requirements.
1.0 Program Background

The concept of CMOM started as a program for wastewater collection that would result in reduced
sanitary sewer overflows (SSOs). A group of wastewater utilities, working with United States
Environmental Protection Agency (USEPA) Region IV (which covers the southeast United States),
started CMOM in 1994 as MOM (management, operations, and maintenance). These utilities and
USEPA believed that many wastewater collection and treatment agencies lacked the tools for
effective planning and management and that having and using such tools would lead to a significant
reduction in SSOs. These utilities also believed that they lacked the financial support they needed
to adequately fund wastewater collection activities and infrastructure. These utilities expected that
CMOM would provide an additional communication tool for the budget planning process and lead
to more appropriate funding for wastewater collection services.
With MOM working successfully in Region IV, USEPA considered adding capacity assurance in
1996 to MOM so that regulations would also address capacity issues. Consequently, the draft
version of federal CMOM regulations would require agencies to evaluate the capacity of the
wastewater collection system and compare that capacity to current and expected flows during dry
and wet weather conditions. Furthermore, adding the capacity assurance piece would ensure that
utilities would identify adequate capital improvements for alleviating capacity bottlenecks that
cause SSOs.
Through a Stipulation with the State of Wisconsin (MMSD Stipulation), the Milwaukee
Metropolitan Sewerage District (MMSD) has agreed to initiate its own CMOM Program by June
30, 2007, and pass rules requiring the 29 MMSD satellite municipalities to develop CMOM
Programs within two years afterward. Whitefish Bay and MMSD are already cooperating to reduce
wet weather flows that contribute to MMSD system SSOs.
The CMOM Strategic Planning Project activities include reviewing Village activities, documents,
and organizational structure from a CMOM perspective. Based upon this review, the Village can
determine which specific areas for improvement exist with respect to proposed CMOM regulations.
Knowing these gaps and Village’s ongoing activities will enable Whitefish Bay to develop a
strategic plan for its CMOM Program.
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Overview of Municipal System

The Village of Whitefish Bay (the Village), located in Milwaukee County, is a satellite
municipality served by the MMSD through 5 primary Metropolitan Interceptor System (MIS)
connections. The Village serves approximately 14,163 people through its collection system which
consists of approximately 204,000 lineal feet of 8-inch to 30-inch diameter sanitary sewers. The
Village does not have lift stations.
The Village’s government is headed by the Village President, who oversees the Village Board. The
Board is the elected body that is fundamentally responsible for making policy decisions for the
Village based upon information received from the Village Manager and Village staff. There is one
committee –Public Works, Utilities & Streets within the Board that reviews projects and programs
regarding utility operations.
The Public Works Department is principally responsible for the operation and maintenance of the
sewer collection system.
Presently the Village projects capital needs ten years in the future updated annually. Rates and
budgets are also reviewed on an annual basis. Funding is provided via the sewer rates.
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1.1.0. CMOM Program Development Process

The CMOM Program is intended to be a continuous cycle, as illustrated in Figure 1-1. The
Village’s CMOM Program will become fully mature only after completing several cycles. The
stages of the CMOM cycle are further described in general terms below:
Figure 1-1. The CMOM Cycle
Status – The Village has participated in a readiness review for CMOM implementation. The
review determined activities and accomplishments that satisfy draft CMOM requirements and areas
for improvement relative to draft state or federal CMOM regulations. The status includes a CMOM
summary of the review.
Strategy – The Village will prepare a strategic plan (the subject of this document) that articulates
how the organization will implement change to satisfy proposed CMOM requirements. The plan
will include the core CMOM topics of service level and regulatory compliance. Service level
describes how the organization will deliver service to its customers and what performance measures
the organization will establish to determine whether the service level goals have been met. Each of
these descriptions explores the options available to the organization for achieving compliance with
the proposed CMOM regulations, but a clear strategic direction is provided for a smooth transition
to the tactics phase. The strategy includes a process for identifying the organization’s CMOM
Program goals and objectives. The strategy also describes how the Village will use asset
management practices to achieve and sustain many of the defined CMOM goals and objectives.
Tactics –During this phase, the organization would develop a Management Plan, Overflow
Response Plan (ORP), Communication and Program Audit Plan, and System Evaluation /Capacity
Assurance Plan (SECAP). As discussed later in this chapter, the Village has already implemented
many aspects of these plans and needs only to document its actions and further improve its efforts
to align with the requirements of the proposed regulations. These plans would provide specific
implementation activities or projects, including adding personnel, modifying information systems,
constructing facilities, or changing organizational structure.
Implementation – During the implementation phase, the Village will undertake a variety of
activities to address the gaps identified in the Strategy phase; including, constructing facilities,
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adopting or refining standards and work processes, and developing data to measure its performance
in carrying out the identified tactics. This phase would also involve implementing standard
management, operations, and maintenance procedures that support compliance with proposed
CMOM regulations.
System Performance – In conjunction with the on-going CMOM phases, the Village will improve
or develop information systems to record and track specific activities and results.
Assessment and Gap Analysis – This phase completes the cycle and results in a status report which
shows the progress made toward complying with the proposed regulations and satisfying the
organization’s CMOM goals.
Following completing the cycle, the process starts again with the Village revisiting its CMOM
status, goals, and objectives. Doing so will ensure that the CMOM Program follows a process of
continual improvement.
The activities covered in this Strategic Plan include the status and strategy phases. Subsequent
contracts or internal Village processes would accomplish the tactics, implementation, and system
performance phases.
1.2.0. Strategy Outline

This Strategic Plan establishes the CMOM strategy for the Village. The remaining chapters
comprising this report define individual strategies for satisfying the strategy phase of CMOM:
Chapter 2 - Management Plan Strategy
The management plan strategy describes the approach the Village is employing to establish the
management plan that meets CMOM Program requirements. The chapter also explains the
compliance readiness review process. A key feature of this chapter documents the goals and
objectives for the Village’s CMOM Program.
Chapter 3 - Overflow Response Plan Strategy
Chapter 3 presents a strategy for a comprehensive overflow response plan that addresses dry
weather and wet weather SSOs.
Chapter 4 - System Evaluation and Capacity Assuranc e Plan Strategy
The SECAP Strategy explains the need to perform system evaluations and to have in place
appropriate capacity assurance tools for wastewater conveyance in order to comply with the draft
CMOM regulations. Components include what is valuable to the Village for this aspect of the
CMOM Program. The chapter explains how the Village will make use of MMSD’s limited satellite
SECAP. This project provides initial steps for an eventual full SECAP if ever required of Village
by WDNR or MMSD.
Chapter 5 - CMOM Program Communication Plan Strateg y
Chapter 5 presents the strategy for communicating the Village’s CMOM Program activities and
plans to all appropriate stakeholders, including customers, regulators, and other interested parties.
The strategy discusses the potential forms and frequency of communication. The Village will need
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to closely coordinate implementing the communications plan strategy with the audit strategy,
presented in Chapter 6.
Chapter 6 – CMOM Program Audit Plan Strategy
The program audit strategy is intended to provide credibility to the Village’s CMOM Program and
establishes a systematic review to determine continuous improvement. The audit plan involves a
rigorous evaluation of the CMOM Program on a regular cycle. Chapter 6 describes the audit
strategy and the time intervals at which audits would take place.
Chapter 7 - CMOM Program Implementation Strategy
Chapter 7 presents the timing for completing each phase of the CMOM Program such that the
Village would satisfy Satellite Stipulation requirements. The CMOM Program will establish
performance measures which include tracking progress in achieving these implementation
milestones.
1.3.0 Potential Regulatory Expectations

Potential regulatory expectations for the Village program are derived from two sources: MMSD
Rules and the Satellite Stipulation. The following text discusses each of these topics separately.
1.3.1. MMSD Rules

In 2007, the MMSD rules will be revised to contain provisions relating to CMOM. The rules will
specifically require all satellite municipalities to have a CMOM Program in place that includes all
of the components identified and discussed in the Satellite Municipality CMOM Strategic Plan.
1.3.2. Satellite Stipulation Requirements

In December 2005, the State of Wisconsin and the Village entered into a Stipulation and Order for
Judgment (Satellite Stipulation). This Satellite Stipulation, unrelated to the previously referenced
MMSD Stipulation, requires that all 29 MMSD satellite municipalities (or “Tributaries” in the
Satellite Stipulation document) would perform or agree to several general activities that would
serve the purpose of reducing SSOs. The following page shows the relative portions of the Satellite
Stipulation.
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[The following is from the Satellite Stipulation between the State of Wisconsin and the Village of Whitefish Bay
FLOW MONITORING SYSTEM, RAIN GAUGE SYSTEM AND PEAK FLOW PERFORMANCE
STANDARD
17. The Plaintiff and the Tributaries agree that the establishment of appropriate flow monitoring and rain gauge
systems and peak flow performance standards for the Milwaukee Metropolitan Sewerage District ("MMSD
Activities") will be useful and important parts of the Tributaries' efforts to avoid future SSOs. The Plaintiff and the
Tributaries further agree, however, that the only practical way for such MMSD Activities to be successfully
established and administered is if they are constructed and managed by MMSD. To that end, the Tributaries agree
that they will encourage and support MMSD’s continuing development, implementation, and management of flow
monitoring and rain gauge systems and peak flow performance standards. Each Tributary retains all legal rights to
object to and appeal any rules and standards implementing such MMSD Activities.
ENFORCEMENT OF SEWER USE ORDINANCES
18. The Tributaries (other than Milwaukee County) shall maintain local sewer use ordinances. By March 1, 2006,
or such other dates as may be provided in applicable WPDES permits, and annually thereafter, each of these
Tributaries shall submit a report to MMSD and DNR documenting that Tributary's actual and effective efforts to
enforce its sewer use ordinance so as to identify and remove illegal connections, including but not limited to
downspouts and footing drains, where applicable.
WASTEWATER STORAGE CAPACITY IMPROVEMENT PROJECTS, SEWER IMPROVEMENT
PROJECTS, AND SEWER MANAGEMENT PROJECTS
19. By no later than December 31, 2006, the Tributaries, except Greendale, shall complete the correction of all
defects identified for correction in the 2010 Limited Sewer Service Evaluation Survey and that are required to be
corrected by current MMSD rules. By no later than December 31, 2007, Greendale shall complete the correction of
all defects identified for correction in the 2010 Limited Sewer Service Evaluation Survey and that are required to
be corrected by current MMSD rules. No later than December 3 1, 2006, however, Greendale shall submit to the
DNR an interim report describing in detail its progress towards completing these corrections.
20. By no later than September 30, 2006, the Tributaries shall inspect externally all sanitary sewer manholes to
identify those subject to surface water ponding and install as needed solid gasketed manhole covers and manhole
frame seals to prevent surface water inflow.
21. By no later than June 30, 2006, each of the Tributaries shall develop and begin implementing a program under
which it will internally inspect each of its sanitary sewer manholes at least once every five years to identify defects
which may contribute to leakage. Furthermore, the program shall require, where cost-effective (as that term is
defined in Wis. Admin. Code I$ NR 110.03(1 I)), the correction of each such defect within eighteen months of
discovery unless demonstrated extraordinary circumstances indicate that a longer period, not to exceed twenty-four
months from discovery, is necessary.
MUNICIPAL CAPACITY, MANAGEMENT, OPERATION AND MAINTENANCE ("CMOM")
PROGRAM DEVELOPMENT AND IMPLEMENTATION
22. No later than June 30, 2009, all Tributaries shall develop and implement Capacity, Management, Operation and
Maintenance (CMOM) programs reflecting the requirements of MMSD1s regional CMOM program, as
contemplated by paragraphs 6-7 of the settlement stipulation in the case of State of Wisconsin v. Milwaukee
Metropolitan Sewerage District, Milwaukee County Circuit Court Case No. 02-CV-270 1.
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1.4.0. CMOM Tactics Which the Village of Whitefish Bay Is Already Practicing
Many of Whitefish Bay’s existing services and activities already comply with anticipated CMOM
requirements. This section identifies those CMOM wastewater conveyance services and activities.
This narrative solely focuses on the existing wastewater conveyance services that state or federal
SSO/CMOM regulations would likely address, should those regulations ever be promulgated.
1.4.1Organizational Structure, Including Administrative and Maintenance Positions
The Department of Public Works is responsible for operating and maintaining the sanitary sewer
collection system as well as many other duties such as snow plowing, landscaping, street sweeping
and other typical public works duties. Currently there is not one person assigned to the collection
system, however several employees have standard job duties that include inspection, cleaning, and
minor repairs. The Director of Public Works is responsible for managing all work including
external contracts. The current organization structure for the Village is shown in Figure 1-2.
Figure 1-2 Village of Whitefish Bay Organization
Director
Of Public Works
Engineering Technician
Public Works Superintendent
Crew Chief
Service Workers
1.4.2Legal Authority to Control I/I and Construction Standards

The Village ordinances include:
• Sewer Use Ordinance
The Village uses and adheres to the State of Wisconsin Construction standards and MMSD Rules.
1.4.3Provide Adequate Maintenance Facilities and Information Management

The Village currently has a scheduled sewer and manhole inspection program for the entire system.
Each year a portion of the system or basin is televised. Village staff reviews and analyzes the data
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and provides recommendations for repairs, rehabilitation and replacement information are
provided. The Village currently cleans the sewers approximately every three years. Historically
the sewers were cleaned every other year, but due to the on-going comprehensive rehabilitation and
replacement projects the frequency was increased to every three years. The frequency is
determined by historical data and a preventive program to ensure no overflows occur to debris.
Flow monitoring is done through MMSD monitors. Permanent flow monitors have not been
installed and based on historical data and information will not have to be installed at this time.
Temporary flow monitoring has been completed by the MMSD.
Village records documenting maintenance activities are completed on paper.
1.4.4Program to Assess the Current Capacity of the Collection

The CMOM requirements for capacity assurance planning require establishing the existing capacity
of the conveyance facilities, determining what obstacles exist for eliminating separate sewer
overflows, and outlining recommendations for implementing improvements. However, properly
constructed models can allow engineers to evaluate the ability of built system capacity to handle a
variety of simulated flow conditions.
The Village of Whitefish Bay participated in the MMSD Limited Satellite SECAP project. In
addition, further comprehensive studies were completed to address the aging infrastructure. Based
on these results and further studies completed by a consultant a comprehensive ten year plan was
developed and has been implemented.
1.4.5Identification of Structural Deficiencies and Implementation of Rehabilitation

Actions
Inspections are reviewed on an on-going basis by a Village Staff and recommendations provided to
repair, replace or rehabilitate the system on an annual basis and incorporated into the ten year CIP.
1.4.6Design Requirements and Standards for the Installation of New Sewers

The Village uses a consultant for all sewer designs who uses and adheres to Standard Specifications
for Sewer and Water – State of Wisconsin and MMSD rules.
1.4.7Monitor, Measure and Update Program Elements as Appropriate

This element of CMOM pertains to the management of the CMOM Program itself. When
implemented, the process will involve reviewing the CMOM Program to determine where
improvements are necessary and establish priorities for those improvements.
As the Village of Whitefish Bay has not fully implemented its CMOM Program, a thorough
updating process has not begun, however, the Village is reviewing the program elements on a
regular basis to revise sewer and manhole inspection and cleaning schedules and to provide
recommendations for repair, replacement for sewers and manholes. In addition to this, the Village
is familiar with processes that measure performance.
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1.4.8Provide a Detailed SSO Emergency Response Plan

The Village currently has a documented emergency response plan for SSOs and have completed
mock drills to ensure Staff responds in accordance with the Standard Operating Procedure (SOP).
The Department of Public Works Director or a designated representative will be enhancing the
written response plan to comply with CMOM. The Plan includes instructions on how to respond,
contact information, staff responsibilities, and notification requirements per WDNR instructions. It
will provide recommendations for developing SOPs such as responding, eliminating, and cleaning
up overflows as necessary.
1.4.9Provide for Public Notification of SSO Occurrences

The Village of Whitefish Bay uses the WNDR overflow response notification form and currently
does not provide public notification. The procedure will be reviewed to determine other
notifications as necessary per Applicable Law.
1.4.10Provide a System Evaluation and Capacity Assurance Plan to Address SSOs

Although the SECAP provision of the draft USEPA SSO rule is not mandatory, the WDNR may
eventually require the Village to develop a SECAP if included in an individual WPDES permit.
MMSD SECAP requirements may also be considered during the development of the Wet Weather
Peak Flow Management Plan. Currently, the Village is in the process of a comprehensive capital
improvement program for structural deficiencies and I/I problems.
As part of the MMSD’s 2020 Facilities Plan project, the MMSD undertook a limited SECAP of
each of the 28 municipalities it serves. The hydraulic evaluations that were performed are limited
in that they analyze only those portions of the local sanitary sewer systems necessary to provide
required information for the 2020 Facilities Plan project. The limited SECAP, which has been
provided to the municipalities, may be used as a starting point for further investigation by the
Village if such investigation is deemed warranted.
The modeling results of the limited SECAP are being used to validate flow development and
overflow volumes for the regional water quality and conveyance models of the 2020 Facilities Plan.
MMSD recommends that the results should not be used qualitatively within the Village system
without further additional analysis. If the Village is required to complete a SECAP at a later date,
and determines that a more complete SECAP will be required, analysis by the Village may need to
include further definition of local flows and sewer system details to support local planning and
design efforts.
1.4.11Conduct a CMOM Program Audit as Part of the Permit Application

The Readiness Review effort conducted in support of this CMOM Program Strategy was an initial
audit of CMOM activities by the Village. Upon implementing this CMOM Strategy, the Village
will be able to conduct future audits. This CMOM Strategy outlines a best practice for performing
such an audit.
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Chapter 2 - Management Plan Strategy

The CMOM Management Plan (MP) describes the means and methods the organization has in place
to ensure complete execution of a CMOM Program. This is the general description of the MP based
on the draft United States Environmental Protection Agency (USEPA) SSO rule and component
CMOM regulations. Although using the draft CMOM regulations as guidelines, this Management
Plan Strategy does not recognize them as a regulation. To the best of the ability of the CMOM
project team, this MP Strategy reflects these draft regulations and industry best practices. In 2003,
MMSD provided all satellite municipalities with an electronic document template for an MP. The
strategy provided on the following pages addresses the content of that template, but the Village will
ultimately need to develop the actual CMOM MP as a stand-alone document.
The MP must satisfy two primary purposes. First, it must serve to achieve the larger CMOM
Program goals that the Village has established. Second, it must satisfy the requirements of MMSD’s
Rules concerning a satellite municipality CMOM Program (currently under development). This
chapter of the CMOM Strategic Plan contains a strategy which outlines the necessary components of
a MP to be subsequently developed by the Village. The Village structured the information for clear
linkage between CMOM Program elements, CMOM Program requirements of MMSD, and draft state
and federal regulations concerning SSOs.
2.1.0. CMOM Program

In the process of performing its first CMOM Readiness
Program
Review, the Village developed goals and objectives for its Goals
CMOM Program. As illustrated in the figure to the right,
the goals are the highest level outcomes that the Village Program Objectives
wants to accomplish through the CMOM Program.
Objectives are statements of how these goals will be
Program Strategies
achieved. Typically there are several objectives that better and Tactics
define each goal. Strategies articulate the specific steps
and tactics involved in achieving each objective. Performance Measures
Performance measures will be used by the Village to
evaluate progress toward achieving each of the strategies, Supporting Data
objectives, and goals.
The MP documents the goals of the program; however, the Village will periodically review the goals
to confirm whether updates are necessary with respect to customer service, regulatory requirements,
and financial considerations. This MP Strategy provides the goals, objectives, strategies that the
Village has chosen for its CMOM Program.
Specifically, the draft federal and state regulations express five general principles that indicate
CMOM compliance for a wastewater utility:
Properly manage, operate, and maintain, at all times, all parts of the collection system that the
utility owns or over which the utility has operational control.
Provide adequate capacity to convey base flows and peak flows for all parts of the collection
system the utility owns or has operational control.
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Take all feasible steps to stop, and mitigate the impact of, SSOs in portions of the collection
system the utility owns or over which it has operational control.
Provide notification to parties with a reasonable potential for exposure to pollutants associated
with the overflow event.
Develop a written summary of the utility CMOM Program and make it available to any
member of the public upon request.
These five general principles serve as a minimum set of objectives for the Village CMOM Program.
The Village has therefore established CMOM goals and objectives in the following fashion:
1. Establish an overall CMOM mission statement that encompasses a desired program outcome
for the wastewater collection system.
2. Establish specific CMOM Program goals for the wastewater collection system.
3. Establish a set of objectives supporting each CMOM goal.
4. Establish strategies and performance measures that support the objectives.
2.1.1. CMOM Program Mission Statement

As a result of this process, the following are recommendations for the Village’s overall CMOM
Program Mission Statement:
Option 1:
“By June 2009, develop and implement a cost-effective CMOM Program based upon best
practices for wastewater collection, which results in cost-effective I/I reduction and
maximizing the ability of the collection system to convey wastewater to the MMSD system
without overflow. The program must be consistent with goals from other Village policies and
ordinances and MMSD Rules and Regulations.”
Option 2:
“To efficiently collect and convey all of our customers’ wastewater in the most cost-effective
manner while remaining in compliance with WPDES permits, Clean Water Act, Wisconsin
Law, and MMSD Rules and Regulations.”
In addition to this, the Village is developing a general mission statement. The Village will develop a
CMOM mission statement during the development of their CMOM Plan. Currently, Village Board
approval for the statement is not required.
2.1.2. CMOM Program Goals

The following CMOM Program Goals were established by Village through this process:
1. Comply with the conditions of the WPDES permit
2. Minimize the occurrence of preventable overflows
3. Maintain assets cost-effectively
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4. Improve or maintain the level of customer service

5. Improve or maintain system reliability
6. Reduce the potential threat to human health from sewer overflows
7. Provide adequate capacity to convey peak flow
8. Manage infiltration and inflow
9. Protect collection system worker health and safety
10. Operate a continuous CMOM Program
2.1.3. CMOM Program Objectives
Each of the CMOM Program Goals identified in Section 2.1.2. requires further definition in terms of
objectives necessary to achieve each goal. Table 2-1 provides the details of the objectives as well as
regulatory expectations that relate to each goal.
Table 2-1. CMOM Program Goals, Objectives, and Regulatory Expectations
Program Goal Objectives Regulatory Expectations
1. Comply with the WPDES Ensure procedures are in place Untreated wastewater
permit concerning sanitary to identify SSOs, report SSOs discharges from the system are
sewer overflows to the WDNR, and mitigate a violation of the WPDES
impacts from the SSOs per the permit.
WPDES permit.
2. Minimize the occurrence of Ensure procedures are in place The WDNR General Permit for
preventable overflows including O&M practices to SSOs provides specific
minimize overflows circumstances under which the
WDNR may not take
enforcement action against the
discharger. These
circumstances include
situations where the SSO
occurred to prevent loss of life,
personal injury, or severe
property damage.
3. Maintain assets cost Ensure preventive maintenance State statutes require
effectively is performed (manholes and wastewater rates to include a
sewer pipes) component for equipment
replacement.
Continue to conduct condition
assessments on sewer assets.
4. Maintain the level of Ensure Customer Service
customer service program is meeting the Village
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needs
5. Improve or maintain system Confirm the existence of any
reliability system components that do not
function according to
established reliability
standards.
6. Reduce the potential threat Identify potential overflows Overflows from the system are
to human health from sewer a violation of the WPDES
overflows • Confirm the existence of permit, Clean Water Act, and
locations where system
Wisconsin State law.
overflows could pose a
threat to human health.
• If such locations exist,
develop response measures
and investigate alternatives
for eliminating the
potential threat.
7. Provide adequate capacity Gain an understanding of the The State would require a
to convey peak flow current system’s ability to System Evaluation/Capacity
convey peak flows and what Assurance Plan for the Village
steps are necessary to address if the evidence shows that the
system inadequacies. system does not possess the
capacity to convey peak flows .
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8. Manage infiltration and Reduce I/I If the State or MMSD
inflow determines a SECAP is
• Understand the current required of the Village, a
level of I/I in the system, component of this plan will
the extent to which it poses include I/I evaluation and
a threat to the regional or reduction.
municipal system
operation, sources of I/I,
and potential remedial
measures.
• Establish a program to
reduce I/I in situations
where I/I results in service
problems, overflows and
building sewer backups or
exceeds peak flow
performance standards
established by MMSD.
Such performance
standards may include
those that would prevent I/I
from increasing in the
future.
9. Protect collection system Provide a safe working
worker health and safety environment for all employees.
10. Operate a continuous Establish procedures for
CMOM Program monitoring CMOM Program
implementation and initiating
program modifications.
CMOM Program Strategies

This section details the strategies developed for the Village. These strategies will be reviewed and
revised as necessary.
1. Ensure procedures are in place to identify SSOs, report SSOs to the WDNR, and mitigate
impacts from the SSOs per the WPDES permit.
• Develop a ORP that addresses the requirements of the WPDES permit and with Applicable
Law. Use the ORP template as a guideline.
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• Review procedures for identifying, reporting, and mitigating SSOs with sewer system staff.
• Continue to use the standard procedure for reporting SSOs
2. Ensure procedures are in place including O&M practices to minimize overflows.
• Review and update manhole and sewer inspection and cleaning programs as necessary
• Continue to perform condition assessments on sewers and manholes to identify areas of I/I
and structural defects
• Review locations of potential overflow or basement backups and provide recommendations as
necessary
• Provide recommendations for future projects as necessary
• Review FOG program and enhance as necessary
• Continue to implement projects that impact operations and overflows
3. Ensure preventive maintenance is performed on manholes and sewer pipes on regular
intervals.
• Review existing sewer and manhole cleaning programs and update as necessary to maintain
the assets.
• Continue to provide recommendations for the CIP based on condition assessments of
manholes and sewer pipes.
4. Ensure Customer Service program is meeting the Village needs.
• Review existing program and provide recommendations for revisions if necessary.
• Coordinate with other Village Departments as necessary
5. Confirm the existence of any system components that do not function according to reliability
standards established by the Village.
• Continue to provide recommendations to the CIP based on the condition assessments
• Review the system to ensure that sewers and manholes are functioning as designed.
6. Confirm the existence of locations where system overflows could pose a threat to human
health.
• Document locations of reported overflows, including basement backups.
• Review each location for the potential to threaten human health and document findings.
7. If such locations exist, develop response measures and investigate alternatives for eliminating
the potential threat.
• Document response measures to be used by municipality staff and contractors in the event of
system overflow. Documentation should be site specific or specific to the type of overflow
(such as a basement backup).
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• Review alternatives, construction-related and operation-related, for eliminating the threat and
document the findings.
8. Identify potential overflows.
• Review system with staff and determine any potential overflow spots
• Provide recommendations for eliminating these overflows if necessary
• Develop response measures if these locations exist
• Develop ORP plan to respond and mitigate overflows
9. Gain an understanding of the current system’s ability to convey peak flows and what steps are
necessary to address system capacity inadequacies.
• Review flow data
• Review basement backup logs
• Identify potential problems through condition assessments
• Develop and implement a SECAP if required to address any identified capacity related
overflows.
10. Reduce I/I.
• Understand the current level of I/I in the system which may include: identifying additional
flow monitoring sites in areas suspected of generating I/I and a wet weather program to
identify areas of I/I
• Implement I/I reduction efforts
• Continue the CIP program to repair, rehabilitate and replace pipe based on the condition
assessments.
• Review and modify the sewer use ordinance as necessary to include illegal connections, FOG,
and any other CMOM related activities.
• Provide recommendations for addressing private property laterals and other connections if
necessary
• Review existing lateral replacement program and provide recommendations for other private
property programs
• Identify and implement projects to reduce peak flows
11. Provide a safe working environment for all employees.
• Continue to provide collection system personnel training on sewer system hazards.
• Continue the existing safety program specific to sewer system work and include specifics such
as sewer system hazards and safety gear.
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12. Establish procedures for monitoring CMOM Program implementation and initiating program
modifications.
• Track the closing of opportunities for improvement identified and prioritized by the CMOM
review
• Update the CMOM Program as necessary or as required by Applicable Law.
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2.2.0 CMOM Readiness Review

In 2004, MMSD hired a consulting team led by Brown and Caldwell to conduct a CMOM Readiness
Review of all 29 MMSD satellite municipalities, including Village of Whitefish Bay. This process,
now completed, involved reviewing documents, interviewing staff, and performing field
observations.
The consulting team developed a framework for the CMOM Readiness Review based on a variety of
sources, including draft CMOM regulations, the MOM checklist from the USEPA Region IV web
site, and information from CMOM experts within Brown and Caldwell. The consulting team
conducted a workshop with managers, engineers, and collection system staff from the Village to
familiarize them with the audit process and to determine primary contacts for the review.
The consulting team collected information for the Readiness Review from documents, staff
interviews, and field visits, using the CMOM checklists as guidelines.
Documents. Village staff provided documents and other information on current practices,
including contract compliance reports, overflow notifications, maintenance activity reports
from the Village’s computerized maintenance management system, and standard operating
and maintenance procedures. Appendix A presents a list of reviewed documents.
Interviews. The consulting team conducted a series of interviews with Village staff . The
interview process encouraged input from all departments that affect the delivery of sewer
service in the Village. The interviews included all Public Works employees involved in sewer
work as shown in the organization chart Figure 1-2
Field Visits. The consulting team conducted field visits with the collection system staff. The
purpose of these visits was to observe field staff work practices and equipment usage. Below
is a listing of the activities observed.
Inspection of sewers
Cleaning of sewers
Other. The consulting team also toured the Village yard to observe the location and quantity
of spare parts, tools, materials, and equipment used for work and for emergencies.
2.2.1 Areas of Improvement and Priorities
Although the Village has a number of documented practices that would meet CMOM requirements,
the Readiness Review of existing practices identified some areas for improvement, mostly related to
documentation.. The consulting team used knowledge of other collection system agencies and results
from benchmarking studies to identify practices that need improvement and documentation. Finally,
Village staff provided their views on practices and areas for improvement during interviews.
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Following this data collection phase, the Readiness Review team reviewed the gathered information
and compared it to prepared checklists to determine specific areas for improvement in practices,
policies, staffing, equipment, facilities, and contracts. Appendix B lists the issues identified by the
Readiness Review and documented in the 2006 CMOM Readiness Review Report. Village staff
established preliminary timing for resolving these issues relative to finalizing the CMOM Strategic
Plan. Village staff intends to address near-term issues within 3 years or less, intermediate within 5
years, and long-term issues within 10 years or less.
During the development of the CMOM Plan, the Village will also identify certain activities that will
require the development Standard Operating Procedures (SOPs). The Village will also continue to
identify and implement projects to improve the condition of the assets and reduction of peak flows.
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Chapter 3 - Overflow Response Plan Strategy

The purpose of a Capacity assurance, Management, Operations, and Maintenance (CMOM)-based
Overflow Response Plan (ORP) is to document a standardized course of action that the Village of
Whitefish Bay wastewater collection system personnel will follow in the event of a sanitary sewer
overflow (SSO) event. To match the recommendations within the U.S. Environmental Protection
Agency’s (USEPA) draft CMOM regulations, the Village would need to enhance its ORP to ensure
that designated personnel immediately dispatch every report of a confirmed sewage overflow to
appropriate field crews to minimize the effects of the overflow with respect to impacts to public
health, beneficial uses and water quality of surface waters, and customer service. Further, the Village
of Whitefish Bay’s ORP would need to include provisions to ensure safety of collection system
workers. Finally, the ORP ensures that the Village notifies and reports overflows to the public and
appropriate local, state, and federal authorities in order to meet Wisconsin Pollution Discharge
Elimination System (WPDES) permit compliance requirements as stated in WI-0047341-04-0
Sanitary Sewer Overflows from Sewage Collection Systems. This chapter of the CMOM Strategic
Plan documents what the Village should incorporate into its ORP. The actual ORP will be developed
by the Village.
In 2003, MMSD provided all satellite municipalities with an electronic document template for an
ORP. The strategy provided on the following pages addresses the content of that template, but the
Village will ultimately need to develop the actual CMOM ORP as a stand-alone document.
Based on a review of documents, including overflow reports, the Village of Whitefish Bay appears to
have a set of operating strategies and documents that meet the intent of the draft CMOM regulations.
Therefore, a CMOM-based ORP for the Village of would consist of assembling these documents,
SOPs and verbal procedures in a single plan, available for review by regulatory staff and the public.
3.1.0. Regulatory Objectives
The objectives of an ORP, according to the draft CMOM regulations, are as follows:
1. Reducing sewer system overflow frequencies and volumes.
2. Protecting public health and safety.
3. Minimizing adverse water quality and other environmental impacts due to an overflow.
4. Avoiding WPDES permit violations.
5. Complying with all local, state, and federal rules and regulations.
6. Protecting public and private property.
7. Minimizing the liability of the collection system owner.
8. Improving the quality of customer service.
3.2.0. Current Activities
Developing and implementing a comprehensive ORP requires a thorough understanding of the
Village of Whitefish Bay’s critical facilities, development of an organizational structure to facilitate
quick response, development of a comprehensive ORP communication plan, maintaining adequate
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dedicated staff and equipment, establishing a panel of outside contractors who can respond to
overflow events, establishing comprehensive reporting procedures, and distributing the plan and
making customers, agencies, and Village personnel aware of the ORP requirements and provisions.
The following is an overview of these topics. The actual Village ORP will provide specific activities
the Village will follow in the event of an overflow.
3.2.1. Critical Facilities Identification
The Village of Whitefish Bay must base its system-wide and site-specific overflow response and
notification procedures on knowledge of Village’s critical facilities and areas of potential impact.
The ORP will identify and list of critical facilities within the collection system. A critical facility is
any structure or component of the collection system that could allow an overflow that would result in
significant impact to public health or the environment. Examples of critical facilities may include
pumping stations, siphons, collector sewers, and areas that may require maintenance on a frequent or
routine basis. Having an ORP that is based on comprehensive knowledge of critical facilities helps
collection system staff to understand the possible cause(s) and potential impacts resulting from a
failure that results in an SSO. While many existing Village operations staff members likely have a
thorough understanding of critical facilities, a properly prepared and updated ORP will serve as an
excellent training tool for new staff.
Thorough documentation of the operational characteristics of each critical facility will assist Village
staff responding to a situation, resulting in a quicker and more efficient overflow response and timely
mitigation of a release. The following section provides brief descriptions of some typical critical
facilities. These descriptions will help Village staff complete the ORP document.
3.2.1.1. Pump Stations
Two types of pump stations covered by this definition are conventional and bypass pump stations.
Conventional pump stations are those that convey flow to a wastewater treatment facility from low-
lying areas in the collection system. Conventional pump stations typically exist in areas where flow
is unable to reach the treatment facility via gravity. Conventional pump stations are considered
critical facilities because a performance failure can result in significant impacts to public health and
the environment. Bypass pumping stations are used in emergency flow conditions to relieve the
hydraulic grade line in the sewer system and prevent basement backups. There are no pump stations
in the Village collection system. At times, the temporary bypass pumps can be used to relief
hydraulic pressures in the system where there is no permanent pumping station. Utilizing bypass
pumping stations ordinarily result in SSOs, although some such systems can discharge to a storage
facility, or a nearby sanitary sewer, if properly equipped.
Mechanical, instrumentation, power, and structural failures at either type of pumping station can
result in basement flooding, surcharged manholes, and overflows of untreated wastewater that may
directly impact public health and receiving water quality.
3.2.1.2. Collection System
The collection system collects and conveys the wastewater from domestic, commercial, and industrial
sources to a WWTP. Collection system deficiencies (e.g., plugged lines, grease build up, root
intrusion, flat slopes, collapsed pipe, hydraulic inefficiencies, etc.) may cause wastewater backups,
resulting in untreated wastewater discharges which can produce adverse public health and
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environmental impacts. According to as-built drawings, the Village owns, operates and maintains
over 204,336 feet of sanitary sewer collection system mains and interceptors. The most critical
elements of the gravity system are shallow manholes and pipes at elevations very close to those of
nearby basements. Village staff has identified the majority of these areas.
3.2.1.3. Siphon
Inverted siphons are sewer lines installed lower than the normal gradient of the sewer line to pass
under obstructions such as watercourses and depressed roadways. Wastewater is “pushed” through
the siphon when the hydraulic pressure exerted by the wastewater in the upstream sewer is higher
than the pressure exerted by the wastewater in the downstream sewer. Siphons generally require
more maintenance than gravity sewers since the velocity of the wastewater carries solids in the
conveyed wastewater up the downstream segment of the siphon. Low velocities will leave heavy
solids at the bottom of the siphon, and maintenance crews must remove these solids by one of several
cleaning methods. For this reason, many organizations construct siphons with two parallel barrels
(pipes) to provide an alternative route for wastewater if one barrel becomes blocked. The Village of
Whitefish Bay does not own any siphon facilities.
3.2.1.4. Diversion Structures
Diversion structures help manage the flow within the system, typically by using gates in open, closed,
or partially open positions. Such structures allow operators to route flow to other portions of the
system that have available flow capacity. The Village of Whitefish Bay has several manholes that are
used as diversion points, but does not own any designed diversion structures.
3.2.1.5.Overflow Gate
An overflow gate (for example, a flap gate) is a mechanism within a regulator used to direct the flow
of wastewater out of the collection system. Overflow gates are critical facilities since failure of the
gate, even during dry weather flow, may allow untreated or partially treated wastewater to be
discharged to a receiving water body. The Village of Whitefish Bay does not own any overflow gates.
3.2.1.6.Storage Tank
A storage tank (or other similar “storage facilities”) can be used in a sewer system to hold back peak
flows during dry or wet weather conditions, effectively reducing the peak flow demands on
downstream sewer infrastructure, such as pumping stations. Such tanks can be constructed above or
below ground. They can be designed to operate with a combination of pumping into and flow by
gravity into and out of the tank. Such facilities can also be a cost-effective means to control
overflows and consequently qualify as critical facilities. The Village of Whitefish Bay does not own,
operate, or maintains any sewage storage tanks.
3.2.2. Organizational Structure to Respond to Overflows and Emergencies

The CMOM-based ORP should contain an organizational chart that provides the names and telephone
numbers of key personnel, the chain of command, and the relationships among various program
components and departments. In addition, the organizational chart should show clear lines of
authority, including the chain of command for responding to SSOs from the receipt of the complaint
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to the person responsible for reporting to the WPDES authority. For the Village, the permit authority
reporting responsibility falls on Director of Public Works (DPW)
3.2.3. Comprehensive ORP Communication Plan
In an overflow situation within the system, the DPW or designated representative will notify others
within the Village, local and state public health agencies, and the public of the situation. Agencies
may require different methods of notification, such as beeper, telephone, fax, and/or written
notification. A comprehensive communication plan allows quick identification of the contact person
and notification procedures. A flow chart should be developed for existing notification procedures
for spills, accidental discharges, and unidentified releases to the Village’s collection system. The
Village routinely performs mock drills to respond to overflows to ensure staff are trained properly.
Public notification is a key component of the communication plan, and a requirement under the new
WDNR general discharge permit, effective March 1, 2006. Also, the draft CMOM regulations
require “notification to parties with a reasonable potential for exposure to pollutants associated with
the overflow event.” SSOs can include bacteria, viruses, toxic constituents, and metals. While
bacteria may die within hours to days following an overflow event, viruses and toxic compounds can
persist in sediments for months after the discharge. Public health concerns arise in areas where
humans, animals, or fish come in contact with overflows.
Public notification often also includes an overflow signage component. Typically, organizations will
use a combination of sign types including: Informational signs at some locations, such as access
points to water bodies; and warning signs at outfall locations. These signs are either fixed (year
round) or event-oriented (e.g., flipped over or inserted into a base or structure during or immediately
following an overflow event). In some cases, organizations will install signs on a seasonal basis.
Implementation issues have included the potential visibility of signs, the ability of agencies to
respond rapidly in the case of event-oriented signage, and the information presented on the signs. If
Village uses warning signs, they should contain universal symbols easily understandable by the non-
English speaking public. Signs should warn the public to avoid contact with the water after a
rainstorm and should include the phone number for contact information. In addition to signage,
organizations use other methods of notifying the public of overflows. These methods include media
advisories following SSO events, web pages, regular newsletters, and hotline (recorded messages)
programs. The Village of has not used these additional methods due to the infrequent number of
overflows. Public notification requirements will be reviewed under the development of the ORP.
State regulations view scheduled (typically related to construction) and unscheduled overflows
differently. The Village reports all unscheduled overflow occurrences to the WDNR according to the
following WPDES permit requirements according to the newly reissued Permit (effective March 1,
2006) for bypasses and overflows from sewage collection systems:
Telephone, fax or by e-mail within 24 hours
Submit a written report within five days using WDNR form or equivalent
By March 31 of that year, document whether or not there was a bypass or overflow in
an annual report.
Additionally, the WPDES permit requires Village to monitor water quality during and after overflow
events. Appendix C includes a summary of the reporting and monitoring requirements of the
WPDES permit.
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This section of the ORP should include requirements and copies of the forms and reports.
3.2.4. Staffing and Equipment Needs
This section describes the types of staffing, staff training, equipment, and collection system
information that the Village of Whitefish Bay should gather, develop, and include in the ORP.
3.2.4.1. Staffing
In order to understand Village staffs’ ability to adequately respond to various overflow situations,
Village should perform an annual inventory of collection systems operations staff levels, shortly after
the start of the calendar year, or sooner if there are significant changes to the organization. An update
at this time will allow the Village to determine if there are critical gaps in human resources needed
for overflow response. The information collected will directly reflect the ability of staff members to
respond to various overflow scenarios. A job description for each position should indicate the
required capabilities of the individual and any additional training or unique certifications that
individuals will need to perform those duties.
Ideally, the staffing information should include the following information for each individual:
Staff name
Department
Years of experience
Qualifications
Day, night, and weekend availability
Phone numbers (home, work, cell, and pager)
Job description
Special training (i.e. confined space entry training)
Certifications
At the same time as it is updating its staffing inventory, Village should update annual organizational
charts that provide the names of individuals and their titles. If appropriate, the annual staff update
should also include agreements with all outside and specialized contractors. Section 3.2.5 provides
further details of this aspect of the ORP. After normal working hours, staff respond as necessary to
all emergencies.
3.2.4.2. Equipment
Before responding to an overflow situation, the responders would need to know the operating
condition of all available portable equipment needed to successfully carry out an overflow response
action. The Village of Whitefish Bay may not need to dedicate equipment to emergencies, making it
available for daily use. The inventory should include the following information describing the
emergency equipment available for overflow response use:
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Name and ID number

Location
Age
Key operating characteristics (voltage, horsepower, etc.)
Contact person responsible for item
o Phone number
o Pager number
Operational status of item
The inventory should include all service and equipment vendors used by Village, phone numbers,
pager numbers, and approximate time to obtain the equipment in the event of an overflow. The
inventory of information should include a copy of each formal agreement.
The ORP must identify the location of the emergency equipment and spare parts. The Village should
also maintain an inventory of critical spare parts for the emergency equipment. The list should
include the location of the critical spare parts, the contact person and phone number, in case field
crews need that part. In some cases, Village may find it more practical to have a redundant piece of
equipment rather than spare parts.
3.2.4.3. Staff Training
The ORP will identify specific training activities that will be required of key individuals responsible
for aspects of ORP implementation. Training will include classroom sessions to review the ORP
contents, conduct desktop training exercises for determining root causes of an overflow, and
reviewing responsibilities for reporting SSOs to appropriate authorities. Field training has currently
been conducted on an on-going basis for Village staff and will be included in the ORP.
3.2.5. External Contractor Support Options
After evaluating the staff and equipment, the instances where outside assistance is required or
beneficial will be evident to the Village. Vendors and contractors are perennial options for equipment
rental or purchase.
As mentioned above, the Village must identify all of its emergency overflow equipment and staffing
needs and then identify all potential vendors and contractors that can supply the equipment and
services. Additionally, surrounding municipalities might make staff and equipment available for
responding to a large overflow. The ORP should also include this information.
Village should require its vendors and contractors to provide, in writing, the time interval required for
their response and the liability coverage that they carry. The vendors or contractors should have
considerable expertise, and, in some instances, certification in the service they provide.
It is difficult to predict emergency expenditures for the coming year, yet the Village must make
funding available for emergencies in order to rectify situations that arise. Village should adjust the
remaining budget amount in the emergency account throughout the year as needed so the ability to
contract for external support is not hindered.
3.2.6. Overflow Response Review
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This section describes the review process, root cause of failure analysis (RCFA), and the process for
developing abatement activities. The ORP will include specific reviews that will occur and who will
be responsible for the reviews following an SSO event.
3.2.6.1. Overflow Response Review Process
Following the overflow event, the Village of Whitefish Bay should conduct a debriefing meeting to
review the response. The purpose of this meeting is to review the response, identify aspects of the
response that went well, problems that arose, and to identify future action all parties should take to
improve the response. Questions that Village should address at the meeting include the following:
What lessons were learned from this overflow event?
Are additional supplies needed?
Are any staffing changes needed?
Are changes needed to the ORP procedure?
After responding to an overflow, it is important to record data about the overflow and the response.
A standardized internal debriefing summary form will help record the information and the Village
should keep the form on file. Figure 3-2 (found at the end of this chapter) shows an example form.
Additionally, staff should prepare an internal report to document the quantity of rainfall.
Subsequently, staff should conduct an RCFA as described below. MMSD generates a substantial
amount of information that may be helpful for overflow event evaluation.
3.2.6.2. Root Cause of Failure Analysis
The manufacturing industry developed the RCFA concept for analyzing process equipment failures.
For wastewater collection systems, the concept can guide development of a methodical and
documented process of determining the root cause of a system failure or overflow with the ultimate
objective of preventing similar failures.
The main elements of a RCFA are as follows:
1. Locating and preserving failure data (such as duration and extent of overflow; monitored
indicators, such as rainfall data, flow data, and water quality data; time of last facility
inspection; and information on previous failures at the specific location).
2. Assembling a RCFA committee to analyze data and develop hypotheses for cause of failure.
3. Verifying hypotheses. The RCFA committee may verify a hypothesis by simply establishing
consensus that existing data confirm a particular hypothesis. Alternatively, the RCFA may
recommend methods requiring further effort, such as hydraulic modeling, for testing a
hypothesis.
4. Determine underlying cause of failure (physical, mechanical, human).
5. Communicate and document RCFA results to management and/or regulating agencies, along
with recommended strategies for preventing similar failures in the future.
The Village’s current practice of analyzing, documenting, and reporting an overflow is thorough. The
Village should develop an SOP for RCFA using the principles outlined above. Such a procedure
would provide a more robust response to establish an affirmative defense in the event of an overflow.
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As a result of the RCFA, the Village may need to perform abatement activities to prevent the
recurrence of the overflow. The nature of the overflow determines what the immediate and long-term
abatement activities are, if any. Short-term steps may be as simple as jetting the sewer pipe to clean
out a grease build-up, or as involved as re-routing the flow of sewage over the course of a few days in
order to repair a pipe.
Long-term abatement activities imply some type of preventive maintenance (PM) on the pipeline.
PM includes cleaning grease build-up from the sewers, I/I removal, clearing out tree roots, or
inspecting sewers with a remote sewer camera. The Village has a PM program for maintaining
problem pipelines and manholes and routinely reviews and updates the list of pipes included in this
program.
The Village of Whitefish Bay uses this information to direct overflow correction activities and
prioritize maintenance activities. A system for retrieving this information could be a particularly
useful resource to those people responsible for preparing collection systems PM programs and capital
improvement plans for sewer rehabilitation and hydraulic capacity projects.
3.2.7. Maintenance and Distribution of the ORP
The Village of Whitefish Bay should make reviews and updates, as necessary, to the ORP to reflect
all changes in the system, policies, and procedures in order to achieve the ORP’s objectives. The
Village must distribute the updated ORP to all personnel who have duties and responsibilities under
the ORP.
3.2.7.1. Review and Update of ORP
The Village should review the ORP annually and amend it as appropriate. In particular, the DPW,
who has primary responsibility for the CMOM Program will:
Update the ORP with the issuance of a revised or new WPDES permit;
Conduct annual training sessions with appropriate personnel; and
Review and update, as needed, the various contact person lists included in the ORP.
3.2.7.2. Distribution of ORP

The Village should distribute copies of the ORP and any amendments to the following
organizations/functional positions:
Wisconsin Department of Natural Resources (WDNR)

Village
o Village Manager
o Department of Public Works
All other personnel who may become incidentally involved in responding to overflows should be
familiar with the ORP. Additionally, the Village should laminate and distribute copies of the
appropriate ORP procedures and contact information to all sewer crews or have them available for
contractors and place them in Village vehicles for reference during an overflow event.
3.3.0. ORP Strategy Considerations
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This section outlines more specifics that the Village CMOM-based ORP should contain.
3.3.1. Determine Level of Detail
The Village needs the ORP to include a level of detail for its system-wide and site-specific
procedures for effective response to SSOs. System-wide procedures provide a description of how the
system operates and operational guidance during high flow events. The site-specific procedures
include response procedures for each critical facility.
3.3.1.1. System-wide Response Procedures
The Village has a documented procedure to respond to overflows. This procedure should be
enhanced to include additional CMOM requirements.
The CMOM-based ORP will require a detailed description of the system-wide operational procedures
for the collection system.
3.3.1.2. Site Specific Overflow Response Procedures
Site specific overflow response procedures consist of one overflow response procedure matrix and
one notification procedure matrix for each type of critical facility. The following information will
serve as the basis for the site-specific matrices.
List of all types of critical facilities
Location of critical facilities
Potential critical facility failures
Potential areas of impact in the event of a critical facility failure
References of the overflow response and notification procedures for each possible failure and
affected area
Figure 3-3, at the end of this chapter, provides an example of a site specific overflow response
procedure. As stated in Section 3.2.1, the overflow response procedures will identify the critical
facilities for which the Village will develop site-specific procedures.
3.3.2. ORP Format
The Village of Whitefish Bay has decided to present the information contained in the ORP to
different audiences in single format. Village should prepare and distribute a comprehensive plan to
staff and regulatory agencies. A web-based format with links to the appropriate procedures, contact
information, and templates for the required paperwork could also present this information. Village
should prepare, laminate, and distribute copies of appropriate ORP procedures and contact
information to each sewer crew and vehicle for reference during overflow events. Appendix D
includes an example outline for the ORP.
3.4.0. Coordination with MMSD and Neighboring Municipalities
Where possible, the ORP should note how and when to involve the MMSD and neighboring
municipalities in response to SSOs. Coordination can range from borrowing of equipment to
notification that an SSO has occurred. The Village has determined that the following coordination
activities will apply to the ORP:
• Village of Shorewood - diversions to and from the Village of Shorewood and Whitefish Bay
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• Public Works Emergency Response Mutual Aid Agreement

3.5.0. Performance Measures for Strategy Implementation
As with other aspects of the CMOM Strategic Plan, the Village of Whitefish Bay has developed
performance measures related to implementing a CMOM-based ORP. The following section
describes these performance measures.
3.5.1. Measurement Parameters
There are two considerations for establishing performance measures for the ORP: effectiveness of
the overflow response and annual review of the ORP. Both are important as several years may pass
between SSO events, making an annual review of the ORP important for ensuring operational
readiness.
Once the Village has completed the ORP and trained staff on its use, the primary measurement
parameters will consider the effective implementation of the ORP procedures during an overflow
event. Also, as the ORP is a living document, the Village should review and update it annually or
more frequently if necessary, to reflect changes in staff, procedures, and general information. The
annual review of the ORP will be conducted by the Village DPW with input from the staff.
The Village will need an evaluation process for the performance measures in order to determine if the
implementation of the ORP is successful. Table 3-1 organizes six performance measures into topic
areas related to the ORP.
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Table 3-1. Desired Results of Performance Measures Overflow Response

Topic Performance Measure
1. ORP Communication Were the proper personnel and agencies notified?
Plan
2. Availability of Staff Were the necessary staff and equipment available? Were the
and Equipment responding crews sufficiently qualified to perform the necessary
tasks? Was the equipment in proper working order?
3. Response Time and How quickly were the crews dispatched to the overflow area? How
Efficiency quickly were they able to contain, control, and mitigate the
overflow?
4. Overflow Response Were the ORPs followed by the responding staff? Were the ORPs
Procedures adequate technically to contain, control, and mitigate the overflow?
Were water quality samples obtained? Were overflow-specific
samples taken? An Example of a Site Specific Overflow Response
Procedure is found in Figure 3-2
5. Root Cause of Were adequate data available to determine the root cause of failure?
Failure Analysis Was the RCFA committee adequately staffed to quickly evaluate the
failure? Was the underlying cause of failure determined? Were
conclusions and strategies for action communicated according to the
RCFA policy?
6. Annual ORP Has the Village updated the communications plan to reflect changes
Reviews and Updates in staff and contact information? Has the equipment inventory been
reviewed and updated? Has the Village documented any changes in
the response procedures?
3.5.2. Communication of Evaluation to Stakeholders

In addition to the normal submission process to the regulatory agencies and MMSD, the Village will
need to make the results of the annual review of ORP performance measures available to all
stakeholders and the general public. The Village may disseminate these updates, and other ORP-
related information, on an internal web site dedicated to CMOM.
The Current notification plan is as follows:

• Incident is called in to Village (DPW or Police)
• Incident is investigated by Public Works Superintendent or designated person. (cause/extent
of incident)
• Superintendent dispatches DPW service workers as necessary and reports findings to the
DPW
• Work is directed to resolve problem either via DPW workers or outside contractor depending
upon the severity of the problem. DPW is notified when work is complete and updates others
as necessary depending upon the severity of the problem.
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• If an overflow, the Village will use their emergency response procedure and they use the
WDNR form to report the overflow and will continue to use this for internal debriefing. A
sample debriefing form is found in Figure 3-1 that can be used for investigation of the
overflow.
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Sample Internal Debrief Summary

Caller/Incident Report
Quantity Released Duration Ref.
Date Spill Started Time Num Reported By Callback Number
hours
Amount Units
Type of Spill (check one) Status of Overflow or Bypass (check one)
SSO Suspected
Petroleum Product Confirmed
Chemical
Biosolids
Other Spill
Location/Address
Information
Overflow Information
Permit Number Regulatory Contact Person and Title Contact Phone Number
Receiving Stream Name or Segment Number (if applicable)
SSO Cause Describe Remedial Measures or Cleanup
Other Comments SSO Preventative Maintenance
Report Taken By Date Signature Reviewer Initials
x x
INTERNAL USE ONLY

AdequateResponse Follow Up Required Site Visit Needed Referred for Enforcement
Figure 3-1. Internal Debrief Summary Form
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CS-2 PROBLEM: Overflowing Sewer Manhole Resulting from Surcharged Sanitary Sewer
OVERFLOW RESPONSE PROCEDURES:
Survey the Scene
Look for any water on the street, sidewalk, grass, dirt, etc. After confirming that the visible water is likely to contain
sewage, look for a receiving storm drain. Follow the path of the sewage overflow to find storm drain entry. Ask for
assistance as needed. Take pictures.
Communicate Findings and Request for Assistance.
Contact the Public Works Department to request assistance for additional staff, equipment, and/ or other agencies.
Report findings to start notification. Call in an additional crew to set up flotation booms across streams, brooks, etc.,
by-pass pumping as necessary.
Set-up of Traffic and Crowd Control
If needed, use cones, barricades, and vehicle(s) to block and divert traffic around the spill and workers. If the
wastewater should jeopardize a playground or park, cordon off the entire area. Close the park to the public until the
issue has been remedied to the satisfaction of the local and state boards of health and the local park superintendent. If
ponding should occur on the street or easement (public or private), cordon off the area.
Attempt Containment
Place rubber sheet at the entrance to storm drain. In some cases you may use two or more rubber sheets if you find that
the storm drain entry is very wide.
Secure Containment in Place
Lay sand bags, sand, dirt, spill pillows or heavy objects at the corners of the rubber mat to keep it in place—thus,
eliminating sewage leaks around the mat and for securing the two overlapping sheets of rubber. Take measurement for
your “Field Spill Report.”
Higher Velocity Spill Flow Downhill
Use absorbent booms/socks, dirt, or sand to build a dam or berm to slow down sewage flow. Install at/or before storm
drain entry.
Divert Spill Back to Sewer Line
By building a small berm to change direction of flow back to downstream sewer manhole.
Constantly Monitor Diverted Spill
Watch for berm leaks and traffic. Keep public out of area.
Divert Spill
Divert spill by pumping out containment area and return sewage to sewer. This set-up requires power source
(generator) and trash (sump pump) and the setting up of traffic control.
Postpone Recovery
Capture spill for later recovery by letting it collect in a natural low area. Recover sewage as soon as time permits.
Figure 3-2. Example of a Site Specific Overflow Response Procedure
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Control Spill
Inspect the terrain configuration. Try to find the lowest area with concrete or asphalt base. (Example: empty parking lot
surrounded by curbs).
Control: Relieve Stoppage
Inspect the downstream manholes until a dry manhole is found and then start jetting or rodding. See standard procedures
for use of combination trucks, vactor trucks, and pumped bypass (emergency power).
Clean-up
Gather and remove debris and organic matter from the affected area. Remove as much of the contaminant as possible.
Remove containment, clean catch basin, and clean channel and creek. Disinfect the ponding areas with an industry
standard disinfectant and notify the surrounding homes.
Assess Damage to Public and Private Property
While the crew is restoring the site, the supervisor/inspector should conduct a preliminary assessment of damage to
private and public property. The focus is to resolve the problem. The supervisor/inspector should use discretion if
advising or assisting the homeowner. The supervisor/inspector should take appropriate still photographs and video
footage, if possible, of the outdoor area of the sewer overflow and impacted area to thoroughly document the nature and
extent of the impacts.
Complete Field Report
Create a field report including sketches of flow path, width, length, and depth. Indicate size and number of manholes,
take pictures.
CS-2 Minimum Levels of Staffing (people): 2-3
TOOLS AND EQUIPMENT SAFETY AND OTHER CAUTIONS
• Jet flushing unit if available (sand trap) • CCTV camera unit

• Rodding machine & associated cleaning/cutting • Truck with hoist
attachments (sand trap)
• Standard disinfectants • Vactor truck
• Safety harness and lifeline if applicable • Power saw (circular)
• Air blower with hose • Pipe cutter (hydraulic)
• Power vacuum • Caution tape
• Portable pumps • Sand trap
• Portable generators • Floatation booms, if necessary
• Safety cones/barricades • Self Contained Breathing Apparatus
• Tritector — for oxygen deficient, explosive or toxic (SCBA)
gases
• Confined space entry tripod and associated equipment
Figure 3-2. Example of a Site Specific Overflow Response Procedure (continued)
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Chapter 4 - System Evaluation and Capacity Assurance Plan Strategy

This chapter provides the strategy for the Village’s satellite municipality System Evaluation
/Capacity Assurance Plans (SECAP) in the event that one is eventually required by MMSD or the
Wisconsin Department of Natural Resources (WDNR). If the Village were to complete its SECAP
according to this strategy, it would meet the requirements for these plans as stated in the anticipated
changes to the MMSD Rules & Regulations concerning satellite municipality CMOM programs.
Such a plan would also likely fulfill federal and state requirements for SECAP. In 2003, MMSD
provided all satellite municipalities with an electronic document template for a SECAP (see
Appendix E). The strategy provided on the following pages addresses the content of that template,
but the Village will ultimately need to develop the actual CMOM SECAP as a stand-alone document,
if required.
4.1.0. Purpose of SECAP
The draft CMOM regulations encompass all aspects of the Village’s wastewater collection
operations. Specifically, the draft regulations state that for Village to be CMOM-ready, it must, as a
minimum, implement or perform the following activities:
1. Properly manage, operate and maintain, at all times, all parts of the collection system that it
owns or over which it has operational control.
2. Provide adequate capacity to convey or store base flows and peak flows for all parts of the
collection system that it owns or over which it has operational control.
3. Take all feasible steps to stop, and mitigate the impact of, sanitary sewer overflows (SSO) in
portions of the system it owns or has operational control as soon as possible.
4. Provide notification that will be available to parties with a reasonable potential for exposure to
pollutants associated with the overflow event.
The draft CMOM Regulations would require that the Village prepare and implement a SECAP if
peak-flow conditions within the separate sewer collection system are contributing to either sanitary
sewer overflow (SSO) discharges or noncompliance at the Jones Island or South Shore Wastewater
Treatment Plants (WWTPs). An SSO occurs when overflow from a sanitary sewer results in a
discharge of untreated or partially-treated wastewater to the waters of the United States. Exceptions
to the SECAP requirement are allowed if the Village has either (1) already taken steps to correct the
hydraulic deficiency or flow conditions causing SSO discharges or (2) the discharges meet
appropriate effluent quality and water quality criteria.
The draft CMOM regulations, which serve as guidance for this strategy, require that the CMOM
Program must include a program to assess the current capacity of the collection system. If the
assessment establishes that the system does not have capacity to convey base and peak flow, then a
SECAP may be necessary. Additionally, the WDNR draft requirements for SECAP 210.24, indicate
that the Department may require permittees to prepare and implement a SECAP, if it is determined
that:
a) peak flows are contributing to SSO discharges, to frequent and recurring basement incidents or
to non-compliance with effluent limits at the treatment plant.
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b) implementation of CMOM Program is not sufficient to attain NR 210.21(1) (SSOs)

The draft CMOM Regulations recognize that there are both legal and hydraulic relationships and
interactions between sewer systems that are connected. While the regulations are not specific as to
how owner/operators of two connected systems should interact, they do require that adequate legal
authority be in place, or be developed, to ensure overall CMOM compliance for both parties.
The latest MMSD Chapter 3 Rules, adopted in May 2007, state that a SECAP could be required by
MMSD if “hydraulic information is necessary to evaluate a sewer design decision or understand
sewer performance.”
At a minimum, SECAP must include four required elements as specified in the draft CMOM
Regulations. These include:
An evaluation of the capacity of the wastewater collection system.
Capacity evaluation measures, documented in a SECAP
Review of the satellite municipality systems (applicable only to the Village system)
Scheduled SECAP updates.
If required by MMSD through the Rules or WDNR by permit, the Village would need to evaluate the
capacity of those portions of the collection system which it owns, or over which it has operational
control. The required evaluations of the system must include the following:
Provide estimates of peak flows, including flows from SSOs that escape from the system,
associated with conditions similar to those causing overflow events.
Provide estimated capacity of key system components.
Identify hydraulic deficiencies, including components of the system with limiting capacity.
Identify the major sources that contribute to the peak flows associated with the overflow
events.
Detailed evaluation of the system will need to be performed under the Village’s CMOM and SECAP
efforts in order to determine if system capacity contributes to SSOs and basement backups. This
evaluation will point to whether capacity enhancement measures are necessary. Such enhancement
measures include increasing conveyance capacity by enlarging pipes and pumping stations,
constructing storage facilities, and reducing I/I.
Capacity enhancement measures include a combination of short- and long-term actions aimed at
addressing each hydraulic deficiency noted from the wastewater collection system evaluation. The
evaluation of alternatives, and subsequent selection, of capacity enhancement measures, should
include:
The process used for prioritizing deficiencies and actions taken to address deficiencies.
A systematic evaluation of a comprehensive set of feasible alternatives for addressing each
deficiency, including estimated costs and performances of various alternatives.
A demonstration that selected alternatives can be implemented from legal, institutional,
financial and management standpoints.
A schedule of key milestones, including proposed start and completion dates, for specific
recommended measures.
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The actual implementation of these short- and long-term capacity-enhancement measures for the
regional system will be developed from and recommended within the ongoing MMSD 2020 Facilities
Plan. The Facilities Plan will provide a limited SECAP analysis of municipal systems where it is
critical to the regional system analysis. As a result, the Village of Whitefish Bay will inherit an
initial, limited SECAP from the Facilities Plan, but Village may need to build upon it in order to meet
regulatory requirements for SECAP.
The SECAP must be updated on a regular basis to describe any significant change in proposed
actions and/or the implementation schedule. The SECAP must also be updated to reflect available
information on the performance of specific measures that have been implemented. In addition to
these requirements, other mechanisms or triggers to warrant SECAP updates could include significant
changes within satellite municipalities of the Village or key sewersheds with respect to population,
land use, and wastewater generation. Such changes could include evaluation of I/I reduction
programs, if implemented.
4.1.1. Overview of Municipal System
The Village of Whitefish Bay, located in Milwaukee County, is a satellite municipality served by the
MMSD through several Metropolitan Interceptor System (MIS) connections. The Village serves
approximately 14,000 people through its collection system consisting of approximately 204,336 lineal
feet of 8- to 30-inch diameter sanitary sewers.
The Public Works Department is responsible for the operation and maintenance of the sewer
collection system.
4.1.2. Municipality Objectives
In addition to the provisions of the draft regulations, the Village has developed its own set of specific
objectives that it wishes to address under the CMOM Program. The Village staff initially developed
the CMOM Program goals and objectives.
One overriding Village objective is to ensure that Village-owned facilities are not the cause of SSOs
or building sewer back-ups.
Four capacity-related objectives have been established:
Comply with the requirements of the WPDES permit.
Reduce overflows including building sewer backups related to system capacity
Reduce I/I .
Comply with MMSD-established peak flow performance standards.
The following section discusses each of these objectives.
Comply with the requirements of the WPDES permit

The WPDES permit, WI-0047341-04-0 Sanitary Sewer Overflows from Sewage Collection Systems,
includes reporting requirements related to explaining what steps have been taken or corrective action
planned to prevent future occurrences of a particular overflow. If a particular overflow is the result of
peak flows exceeding the capacity of the sewer system, the satisfying this WPDES permit
requirement could be an important objective for SECAP evaluations on a portion of the system.
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Reduce Overflows
The elimination of SSO discharges are key objectives of the Village, MMSD, and the public.
Reduction of these discharges may improve receiving water quality.
Reduce I/I
The Village will continue to pursue identifying and reducing excessive I/I levels in its system.
Comply with MMSD Established Peak Flow Performance Standards

To meet the requirements of the MMSD Stipulation, the MMSD will complete its recommended 2020
FP alternative by December 31, 2006. The MMSD will also complete its implementation plan for the
2020 FP which will be coordinated with the Regional Water Quality Management Plan Update being
completed by the Southeastern Wisconsin Regional Planning Commission by April 2007. It is
anticipated that the Wisconsin Department of Natural Resources, according to the requirements of the
MMSD Stipulation, will issue its final determination on the 2020 FP by December 31, 2007.
In addition to identifying facilities, the 2020 FP will recommend “POP”s – Policies, Operations, and
Programs. Two of the Programs that are recommended under the 2020 FP include the satellite
municipality CMOM programs and the Wet Weather Peak Flow Management Program.
Concurrent with the development of the recommended 2020 FP, the MMSD is in the process of
amending its rules to require satellite municipalities to implement and have continuous CMOM
programs.
The Wet Weather Peak Flow Management Program (WWPFMP) will define: (1) flow and
precipitation monitoring programs; (2) peak flow performance standards; and (3) enforcement
activities.
Peak Flow performance standards that will be established under the WWPFMP will require
municipalities not to exceed peak flows established in the 2020 FP to ensure that the capacity of the
regional system is adequate to meet the needs of the region through the planning period for the level
of protection against sanitary sewer overflows established for the 2020 FP. In addition, the
WWPFMP will establish standards to limit peak flows for defined geographic units (the geographic
unit could be a municipality, meter basin area, or MIS connection tributary area) to some maximum
value that is defined relative to the average values for all geographic units in the MMSD service area.
The Program to monitor and enforce peak flow standards will be developed in a collaborative fashion
with the satellite municipalities.
The 2020 FP will evaluate system-wide infiltration and inflow (I/I) and, as part of the Wet Weather
Control Plan, will identify the cost-effective level of I/I reduction system-wide and for specific areas
requiring MIS relief. The peak flow performance standards to be developed by the WWPFMP will
consider the peak flows and I/I levels defined for facilities sizing as part of the Wet Weather Control
Plan.
4.2.0. Activities of MMSD Satellite Limited SECAP Analysis Project
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In 2004, the MMSD hired a consultant to perform a limited SECAP analysis of all satellite
municipality systems. This project was limited in the sense that a) it typically only analyzed the
capacity of 12-inch diameter and larger pipes, b) identified satellite municipality system capacity
deficiencies; c) estimated satellite municipality system bypass volumes and flow rates for a selection
of wet weather events, and d) it did not evaluate any potential remedies to capacity problems.
Specifically, the objectives of the limited SECAP project within each municipality were:
• Identify satellite municipality system capacity deficiencies.
• Estimate satellite municipality system overflow volumes and flow rates for a selection of wet
weather events that are relevant to the 2020 Facilities Plan analysis
• Summarize peak flows delivered to MMSD’s system for the same wet weather events.
MMSD has provided the Village with a full copy of the Limited SECAP report as well as any
modeling data that would be useful for further analyzing the Whitefish bay system. Figure 4-1 shows
the Village of Whitefish Bay service area, 2020 Facilities Plan sewersheds, and the extent of the
Whitefish Bay system modeled in the Limited SECAP project. The results of the project are found in
the limited SECAP report itself and according to MMSD should not be used quantitatively without
further additional and detailed analysis.
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Figure 4-1. Village of Whitefish Bay Sewer System Modeled in the Limited SECAP Project
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4.3.0. SECAP Implementation Strategy

The previous sections of this chapter outlined the draft requirements for SECAP based on the draft
CMOM Regulations. This section describes the SECAP Strategy and how the Village will implement
it if required by MMSD or WDNR. The paragraphs below present a general discussion of the
strategy, followed by a specific set of actions for the Village.
The root causes of the SSO discharges are typically physical, hydraulic, or operational deficiencies
within the regional and local collection systems; and according to the draft CMOM regulations, SSOs
must not occur. That said, a collection system owner can get relief from an
Review Design enforcement action if it can prove that a severe natural event caused the discharge and
Criteria the collection system owner took all reasonable steps to prevent the discharge. These
reasonable steps include considerations within the SECAP Strategy, namely: capacity
increases and I/I reduction. In order to prevent SSO discharges, critical portions of
the collection system will be evaluated with a focus on determining the causes of the
discharges. After identifying the causes of the SSO discharges, the Village will take
Evaluate System the necessary steps to correct the problems.
Hydraulics
The key strategies to meet SECAP objectives include: evaluating the collection
system; determining system deficiencies or other related capacity problems;
evaluating capacity-enhancement measures and their prioritization; implementing
capacity enhancement or I/I reduction measures, and managing the capacity allocated
Perform Field I/I to inter-municipality connections (if they exist). Specific tactics to achieve these
Investigations strategies are outlined as follows, in the recommended order of priority:
1. Review the Village design criteria related to system capacity.
2. Evaluate Village’s conveyance system using hydraulic analysis tools.
Evaluate Flows 3. Perform any appropriate field investigations in sewersheds where peak flows
Relative to MMSD appear to exceed the MMSD Peak Flow Performance Standard or where I/I
Standards contributes to local or regional SSOs.
4. Evaluate system flows relative to MMSD Peak Flow Standards.
5. Evaluate the impact of satellite municipality discharges to the Village system.
Evaluate Impact of 6. Evaluate a wide range of capacity-enhancement and peak flow reduction
Satellite System measures, based on the modeling, monitoring efforts, and field investigations.
Discharges 7. Develop a Capital Improvement Program (CIP) list of capacity enhancement
projects, including a basis for establishing implementation priority.
8. Produce a SECAP document that details the subsequent steps and an approach
Evaluate Projects for evaluating the effectiveness of projects after they are completed.
to Resolve
Conditions 4.3.1. Recommended Tactics if SECAP Is Required
Tactic 1: Review Design Criteria
Design criteria indicate the level of service that municipal systems use for sizing
conveyance facilities. This action is a good first step for reviewing system capacity
Develop CIP and opens a dialog with the Village governing body as to what capacity changes may
be needed to resolve local system SSOs. This level of service selection by the Village
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for its system needs to consider what MMSD is providing for regional level of service, per its most
recent facilities plan.
Tactic 2: Evaluate Available System Capacity
The evaluation of the Village of Whitefish Bay’s wastewater collection or conveyance system is a
critical component of SECAP. An initial activity will involve evaluating historical SSOs and
activities already undertaken to resolve their root causes. The analysis tools used in this action item
could include the models being used by the 2020 FP Limited SECAP Analysis Project. The overall
objective of this action is to determine where system deficiencies contribute to SSO and building
sewer back-ups. This evaluation may necessitate additional local system flow monitoring.
Monitoring of wastewater collection systems, or system monitoring, is an integral component of
system management and operation. Monitoring can be used to:
Evaluate daily, seasonal, and long-term trends in wastewater flows.
Track reductions in rates of I/I and occurrences of overflows as the result of sewer
rehabilitation and other system physical or operational improvements.
Calibrate and verify sewer system models.
Gain an overall understanding of how the system responds and operates under varying
groundwater levels and climatic conditions.
Once adequate flow data are available, the modeling tools can be calibrated for better evaluation of
system hydraulics under dry and wet weather conditions. Situations such as manhole overflows,
system surcharge, and building sewer backups can be evaluated with a calibrated model.
If the Village is required to do a SECAP, it will likely be allowed to focus on SECAP evaluations in
the affected areas. This process will likely include addressing the problems identified at the points of
discharge to the MMSD system. Having a clear understanding of how the MMSD will establish
capacity and level of service goals and objectives for its conveyance system will be key inputs to the
Village SECAP Programs. From this information, the satellite municipalities can then plan for I/I
control, other CIP, and operational improvements within their systems.
If required by MMSD rules, the Village may need to determine how its collection system performs in
terms of occurrence of building sewer back-ups and overflows, and in ratios of peak-to-average flows
and actual rates of I/I. MMSD’s I/I control guidance will be a major benefit to the Village as it
begins to evaluate and ultimately mitigate capacity and other deficiencies within their respective
systems.
The Village will need to determine if the modeling performed under the Limited SECAP project is
sufficient to meet the objectives of the full SECAP. The primary consideration is whether all known
system bottlenecks were included in the analysis. If not, the Village will need to expand the
modeling or analysis to include these additional areas. The Limited SECAP did not consider future
flows from additional connections. As a result, the Village will want to incorporate future flows into
the SECAP analysis, particularly if significant changes in population or employment are anticipated.
Tactic 3: Perform Field Investigations in Sewersheds
The control of I/I within the satellite municipality collection systems is a key issue in the overall
context of SECAP. Within the MMSD service area, I/I is the primary cause of most SSO discharges.
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I/I control is also a fundamental tenet of CMOM as I/I affects system capacity; it needs to be properly
managed; its detection and control is part of good system operations; and it can be reduced by proper
maintenance.
Field investigations can include all or portions of the following: rainfall gauging, sewer system and
groundwater level monitoring, physical and closed-circuit television (CCTV) inspection, smoke
testing, dye studies, and other field testing and inspection procedures. Recommendations for these
best practices, and effectiveness evaluations, have been published by the Water Environment
Federation (WEF), Water Environment Research Foundation (WERF), American Society of Civil
Engineers (ASCE), and USEPA. In 1981, during the WPAP, MMSD published the Private Property
Infiltration/Inflow Pilot Project Report, which documented the findings of small scale I/I
investigations and established parameters for sizing facilities relative to anticipated future I/I. The
Village last undertook complete SSES investigations in 1980s and more recently in 2001 and 2003
performed a limited SSES (LSSES) by doing manhole inspections, smoke testing, and flow
monitoring.
In order to ensure maximum usefulness, the Village will need to ensure proper management of data
collected under flow monitoring programs. Data management includes the collection, QA/QC,
storage, and useful reporting of data. For example, a good data management system allows for
straightforward transfer of data into sewer models or other analysis
The Village already has a significant amount of condition data on its collection system through the
on-going inspection program.
The Village has used the data that was collected and analyzed for the evaluations, or collected
through the field investigations. The Village may choose to manage the data with a fully-functional
GIS. For example, in the next round of field investigations, the Village could capture data in a format
that is compatible with the GIS. Implementing this recommendation would improve the usefulness of
the next inspections for engineering evaluations.
Tactic 4: Evaluate System Flows Relative to MMSD Peak Flow Performance Standards
The 2002 Stipulation (MMSD Stipulation) entered into between the State of Wisconsin and the
Milwaukee Metropolitan Sewerage MMSD (MMSD) states that the MMSD must develop the 2020
Facilities Plan (2020 FP), including development of a Wet Weather Control Plan. Additionally, the
stipulation requires the MMSD to implement a CMOM program and to require by MMSD rules that
the satellite municipalities develop a local CMOM program within two years after completion of the
MMSD’s regional CMOM program.
To meet the requirements of the MMSD Stipulation, the MMSD will complete its recommended 2020
FP alternative by December 31, 2006. The MMSD will also complete its implementation plan for the
2020 FP which will be coordinated with the Regional Water Quality Management Plan Update being
completed by the Southeastern Wisconsin Regional Planning Commission by April 2007. It is
anticipated that the Wisconsin Department of Natural Resources, according to the requirements of the
MMSD Stipulation, will issue its final determination on the 2020 FP by December 31, 2007.
In addition to identifying facilities, the 2020 FP will recommend “POP”s – Policies, Operations, and
Programs. Two of the Programs that are recommended under the 2020 FP include the satellite
municipality CMOM programs and the Wet Weather Peak Flow Management Program.
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Concurrent with the development of the recommended 2020 FP, the MMSD is in the process of
amending its rules to require satellite municipalities to implement and have continuous CMOM
programs.
The Wet Weather Peak Flow Management Program (WWPFMP) will define: (1) flow and
precipitation monitoring programs; (2) peak flow performance standards; and (3) enforcement
activities.
of protection against sanitary sewer overflows established for the 2020 FP. In addition, the
WWPFMP will establish standards to limit peak flows for defined geographic units (the geographic
unit could be a municipality, meter basin area, or MIS connection tributary area) to some maximum
value that is defined relative to the average values for all geographic units in the MMSD service area.
The Program to monitor and enforce peak flow standards will be developed in a collaborative fashion
with the satellite municipalities.
The 2020 FP will evaluate system-wide infiltration and inflow (I/I) and, as part of the Wet Weather
Control Plan, will identify the cost-effective level of I/I reduction systemwide and for specific areas
requiring MIS relief. The peak flow performance standards to be developed by the WWPFMP will
consider the peak flows and I/I levels defined for facilities sizing as part of the Wet Weather Control
Plan.
As suggested in the Satellite Stipulation, MMSD will construct and operate any metering facilities
needed to determine a sewershed’s compliance with the standards. The Village may need to evaluate
how to reduce peak flows in sewersheds found to exceed the standard.
The Village has ongoing initiatives that address peak flow reduction or volume reduction.
• Ongoing sewer and manhole inspection program
• Ongoing rehabilitation and replacement program
• Review ordinances and legal programs to ensure that private property programs can be
effectively are addressed. The Village recently updated their ordinance to require property
owners to replace defective laterals.
The Village will need to carefully review and assess practices for I/I control relative to site specific
conditions. Variables to consider when evaluating such standards include the occurrence of basement
back-ups and/or surface flooding, soil and groundwater conditions, age and construction material of
the collection system, experience of local contractors in certain types of sewer system rehabilitation,
and other site-specific factors.
The knowledge gained within these efforts will allow the Village to develop a SECAP Program
which focuses its attention on identified problem areas. For instance, storm sewer evaluations may
indicate that inadequate storm systems are contributing to excessive I/I during extreme events. Once
the relationships are understood between storm sewer flooding and I/I, SSOs, or basement back-ups,
the Village may need to address capacity issues through CIPs. This information can also provide
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valuable input into the Village storm water management programs being developed in response to the
USEPA Phase I and Phase II Storm Water Management Regulations.
Tactic 5: Inter-Municipality Connection Review

Understanding the impact of inter-municipality connection discharges from another municipality to
the Village system could be key to understanding and eventually mitigating certain SSO discharges.
This understanding may require monitoring and hydraulic modeling of the inter-municipality
connection discharges to the Village system. The Village of Shorewood discharges to the Village
system and vice versa. When developing its SECAP, the Village should consider whether monitoring
satellite discharges should be performed.
By having a fuller understanding of the possible causes of system flooding and overflows, or back-
ups, the Village can then apply the necessary technical and financial resources in its SECAP
Programs to targeted mitigation efforts. Steps could include negotiating specific agreements with
satellite systems regarding the amount of base and peak flows they are allowed to discharge to the
Village system at each connection.
Tactic 6: Evaluate Alternatives for Capacity Enhancement and Peak Flow Performance
Standards Compliance
Using the models or capacity analysis tools, the Village will analyze alternatives for resolving
capacity issues. The Village will also use the tools to evaluate the extent of I/I reduction that may be
needed to comply with local system or MMSD peak flow performance standards in affected
sewersheds. Alternatives that the Village could evaluate in this action include increased capacity in
pipes and force mains, storage facilities, and I/I reduction projects. It will be important for the
Village to consider how any additional future wastewater flows in its service area would impact this
analysis.
Tactic 7: Develop a Program for Resolving Capacity Problems and Reducing Peak Flows
Based on Action 5, the Village will detail the projects or actions needed to resolve capacity issues and
compliance or may consider other peak flow performance standards as necessary or as required by
Applicable Law (including MMSD Rules). The Village will need to estimate the cost of these
projects and establish how the projects will be prioritized in the capital budget.
Tactic 8: Produce SECAP Document
This step will involve documenting the previous 7 actions in a plan that states what activities the
Village will embark on to resolve local system SSOs and comply with MMSD Peak Flow Standards.
It will recommend the activities needed to achieve the goals of the SECAP and will document the
relative priority of each activity. If deemed necessary, the Village will include any new or modified
satellite system agreements identified in Action 5. The form of the SECAP document will follow the
template developed and provided by MMSD in 2004.
4.4.0. SECAP Performance Measures
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This final section of the SECAP Strategy addresses performance measures. In order to determine
how well Village is implementing the SECAP Strategy and the derived benefits, Village should
establish and track a set of definable measures for such purposes.
A regular review process is critical to collecting and reporting on performance measures. Therefore,
the periodic review of the performance measures needs to be a process that is made available to all
stakeholders and the general public. The Village could disseminate these updates, and other SECAP-
related information, on the Village web site in an area dedicated to CMOM.
4.4.1. Collection System SECAP Performance Measure Definitions
There are seven potential performance measures for the collection system SECAP. These include:
1. Hydraulic capacity evaluation of conveyance system.
2. Activities needed for SSO reduction.
3. Regular updates of the capacity evaluations and CIPs in response to significant system
changes.
4. Volume of rainfall captured (for the system or individual sewersheds).
5. Ratio of peak-to-average flow (for the system or individual sewersheds).
6. Number of Sewersheds Exceeding the MMSD Peak Flow Performance Standards.
7. Reduction in SSO volume (for the system or individual sewersheds).
Completion of Hydraulic Capacity Evaluation of Conveyance System

This is a key to the overall SECAP Strategy as the hydraulic capacity of the conveyance system will
establish the rates of flow, and volumes, that the system can accommodate. This evaluation, which
will result in the determination of factors contributing to SSO discharges, is a high priority task. Its
execution will be a key measurement of SECAP performance. WDNR and MMSD may require this
evaluation be done only on the part of the system relating to historic SSO locations.
CIPs for Needed Overflow Reduction

The capacity evaluation will reveal points within Village’s conveyance system where it cannot
accommodate dry or wet weather flow. From this information, recommendations to increase the
capacity of the conveyance system, decrease the peak flow, or combinations of the two will be
implemented via the CIP.
Regular Updates of the Capacity Evaluations and CIPs in Response to Defined Triggers
The draft CMOM Regulations would require periodic updates of the Village’s SECAP. Having
defined triggers for such updates will be important to ensure adequate management of overall system
capacity. Specific triggers within key municipalities or sewersheds to warrant such updates could
include population growth or increases in commercial or industrial activity, increases in dry weather
flow, increases in the ratio of average-to-peak flows, increases in overflows or building sewer back-
ups, and others as determined by the stakeholder groups. One measure of SECAP performance will
be how well the Village ultimately implements this update process.
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Volume of Rainfall Captured to Track I/I Control Success

The measurement and tracking of the volume of rainfall captured by the separate sewer system is a
very simple and meaningful measure of SECAP performance. The analysis will use rainfall, flow,
and overflow volumes data [Insert fuller description here], but it should normalize them to reflect
yearly and seasonal climatic and precipitation variability. Overall, a decreasing rate of rainfall
capture indicates progress in I/I reduction programs.
Ratio of Peak-to-Average Flow Ratios to Track I/I Control Success

Another measure of SECAP success is the measurement and tracking of the ratio of peak-to-average
flows from key points throughout the separated portion of the regional system. If the Village were to
implement I/I control measures, peak rates of flow from the system, should decrease. Thus, this
tracking provides a good measure of SECAP performance. If known to have sewersheds with high
groundwater infiltration, other measures may be more meaningful.
Number of Sewersheds Exceeding the MMSD Peak Flow Performance Standards

of protection against sanitary sewer overflows established for the 2020 FP. The Village will need to
track the number of its sewersheds that exceed the standards and work to reduce the number in this
category through its SECAP implementation, if required.
Reduction in Overflow Frequency and Volume to Track I/I Control Success

Tracking actual reduction of separate sewer overflow frequency and volume are the most direct
measurement of the success of SECAP and the Village I/I control efforts.
4.4.2. Evaluation of Performance Measures

The six potential performance measures also need to have an associated evaluation process in order to
determine if the implementation of the SECAP is successful. Table 4-1 summarizes the desired
results for each performance measure.
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Table 4-1. Desired Results of Performance Measures Wastewater Collection System
Measure Desired Result Annual Report

1. Hydraulic Evaluation Determination of hydraulic restrictions/ Status and findings.
causes of flooding and overflows.
2. CIP for SSO Reduction Reduction in SSO volume and frequency. Status of implementation.
3. Update Triggers for Capacity Ensure SECAP updates in response to Tracking of defined triggers/
Evaluations/CIPs changes in hydraulic regimes.
Status of updates
4. Volume of Rainfall Captured in Reduction in rainfall capture. Tracking of rainfall capture.
Separate Sewer System
5. Peak-to-Average Flow Tracking Reduction in peak-to-average ratio in Tracking of flow ratios.
separate sewer area.
6. Number of Sewersheds Exceeding Reduction and eventual elimination of Tracking of sewersheds
the MMSD Peak Flow Performance sewersheds exceeding the standard
Standards
7. SSO Reduction Tracking Reduction in SSOs volume and Tracking of SSO performance.
frequency.
The Village should evaluate performance for each of the performance measures selected on an annual
basis, until the problems identified in the SECAP are addressed.
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Chapter 5 - CMOM Program Communication Plan Strategy

The CMOM Program Communication Plan (CP) articulates the process for reporting to various
stakeholders the implementation activities and performance of the Village of Whitefish Bay’s
CMOM Program. This chapter states the objectives for communications and a set of complementary
strategies for achieving those objectives. In addition, this chapter also provides performance
measures for communications strategy implementation. In 2003, MMSD provided all satellite
municipalities with an electronic document template for a CMOM Program Communications and
Audit Plan (see Appendix F). The strategy provided on the following pages addresses the content of
that template, but the Village will ultimately need to develop the actual CMOM CP as a stand-alone
document.
5.1.0. Purpose of Communications Plan
The CP articulates the process for reporting to various stakeholders the implementation activities and
performance of the CMOM Program. This plan should state the objectives for communications and
describe a set of complementary strategies for achieving those objectives. Performance measures for
communications strategy implementation should also be provided in the plan.
The recommended objectives of the CP are as follows:
Facilitate internal reporting on CMOM Program progress to employees;
Provide information on CMOM Program progress to stakeholders;
Report on short-term, long-term, and cyclical CMOM Program actions;
Coordinate with other municipality and MMSD communications initiatives; and,
Satisfy CMOM regulatory requirements for program communications, including any
requirements of the Satellite Stipulation.
5.2.0. CMOM Program Stakeholders

CMOM Program stakeholders will include internal and external groups and individuals. The Village
has identified the following internal stakeholders to the CMOM Program:
• Governing Body
• Public Works Department
• Public Health Department
The Village has identified the following external stakeholders to its CMOM Program:
• MMSD
• WDNR
5.3.0. Communications Strategy

A specific set of strategies will, when implemented, satisfy the objectives identified above. Where
possible, the strategy identifies and assigns specific actions to organizations, divisions, or individuals.
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5.3.1. Develop Communication Plan

The CP will outline the type and frequency of publications and briefings related to the CMOM
Program. The CP should also include a report to inform various interested parties, including internal
audiences such as Village staff, and external stakeholders including MMSD, state and federal
regulators, and ratepayers. Primarily, the report should be updated on an annual basis. A separate
report will be generated when an overflow is reported to regulatory officials. The CP will define the
purpose, content, and format for all CMOM Program-related reports. The CP will also identify
synergies between the CMOM Program and other projects and communications initiatives. Finally,
the plan will include a process for reviewing and updating the CP.
5.3.2. Assign Staff Responsibilities
Developing and implementing the CP will require staffing resources. The Village will need to assign
staff to tasks such as developing the plan for cyclical and incident-driven publications, planning and
facilitating communication events (e.g. Commission meetings, municipal meetings, etc.), updating
the plan, preparing the budget inputs, and coordinating with other Village projects and initiatives.
The Director of Public Works or designated representative will manage production of these plans and
reports but will rely on contributions from staff.
5.4.0. Communication Plan Reports
This section describes the various documents that the CMOM CP will require and govern. The
CMOM Program annual report is a document that presents a summary of the program
accomplishments for the year and a summary of the planned actions and initiatives for the next year.
This repost is for both internal and external audiences, as the annual report will be available to the
public and is consistent with the annual reporting recommendations of the draft federal CMOM
regulations. The Village annual report will contain a discussion of the CMOM performance measures
comparing the actual data result for the year versus the plan target and versus last year’s performance.
MMSD is developing rules that will likely require submitting an annual report for MMSD review. At
this time, MMSD does not anticipate requiring a separate annual CMOM report, but instead request a
CMOM update as part of other reporting requirements, such as the I/I plan updates.
5.4.1. CMOM Program Five-Year Audit Report
The CMOM Program five-year audit report will update the CMOM benchmark data. The Village
will measure the program’s performance by comparison to the target values and similar
measurements from the previous report. Chapter 6 of this Strategic Plan provides further discussion
of the Audit Report.
5.4.2. Regulatory Reporting
The Village of Whitefish Bay’s current Wisconsin Pollutant Discharge Elimination Program
(WPDES) permit requirements specify overflow reporting on both a cyclic and incident-driven basis.
The WDNR requires quarterly reports for all overflows during the preceding three-months. Incident-
driven reporting includes 24-hour notification and a five-day report. The Overflow Response Plan
(ORP) Strategy, Chapter 3, describes these reports in detail.
Starting in 2006, WDNR required all municipal collection system owners to perform and submit a
self-audit of their practices relative to managing the system. This process is called the Compliance
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Maintenance Annual Report (CMAR). The CMAR includes questions pertaining to the components
of the Village’s CMOM Program. Each year, the Village will use CMAR to update WDNR on its
CMOM Program activities.
5.4.3. Village Board Briefings
Briefings will provide an opportunity for Village staff to present information on the status of the
CMOM Program to its Village Board. These briefings will be important to ensure continued support
for CMOM Program implementation.
5.5.0. Performance Measures
Performance measures are needed to evaluate the CP implementation. These recommended measures
are:
Number of internal and external stakeholder briefings per year
Number of Village Board briefings per year
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Chapter 6 – CMOM Program Audit Plan Strategy

The Village intends to audit the CMOM Program to evaluate the program’s implementation and
performance. The draft CMOM regulations released by the USEPA included requirements to submit
an audit report to the permitting authority. If MMSD passes new Rules requiring CMOM Program
audits, the Village will submit such an audit report to MMSD. Typical participants in the audit
include the National Pollution Discharge Elimination System (NPDES) permitting authority, WDNR,
health officials, members of the affected public, and other interested parties. The audit covers the
program's compliance with permit requirements (if any), any identified deficiencies, and steps to
address them. In 2003, MMSD provided all satellite municipalities with an electronic document
template (see Appendix F) for an CMOM Program Communications and Audit Plan (AP). The
strategy provided on the following pages addresses the content of that template, but the Village will
ultimately need to develop the actual CMOM AP as a stand-alone document.
6.1.0. Purpose of CMOM Audit
The CMOM Program AP establishes a process for reviewing and evaluating the performance of the
CMOM Program and implementing needed changes.
The objectives of the AP are as follows:
1. Solicit suggestions and obtain stakeholder input.
2. Allow for periodic review and changing of CMOM Program according to input and
benchmarking data.
3. Establish processes for changing the CMOM Program according to results of periodic review
with respect to performance measures.
4. Reflect CMOM implementation status within the audit process.
5. Provide data to the Communication Plan regarding plan changes in order to demonstrate that
the CMOM Program is being regularly updated.
6.2.0. Audit Implementation Strategy
The Village can employ several specific strategies to satisfy its CMOM Program audit objectives and
the audit recommendations of the draft federal CMOM regulations. The draft regulations state:
§ 122.42 (e) (2) (ix) CMOM Program Audits. As part of the NPDES permit application,
you must conduct an audit, appropriate to the size of the system and the number of
overflows, and submit a report of such audit, evaluating your CMOM and its compliance
with this subsection, including its deficiencies and steps to respond to them.
Using the draft federal CMOM regulations as guidance, the Village intends to produce a CMOM
audit report approximately every five years. However, the CMOM Program maybe updated through
performance measures on a more frequent basis.
6.2.1. Develop a Conduit to Solicit Suggestions
Methods to solicit suggestions and updates should be considered to update the plan. One method
could a “suggestion box” for CMOM Program improvement recommendations. The Village could
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make it possible for staff members to make comments anonymously, including those specific
suggestions relating to the member’s CMOM responsibilities. The DPW will review these
suggestions and determine potential actions. Chapter 2, Management Plan Strategy, recommends
Village set up a CMOM work team to support the Director of Public Works. Upon request of the
Director of Public Works or designated representative, the team would also review the suggestions to
determine potential actions and issue responsibilities for following up on the suggestion.
6.2.2. Review and Program Change Procedures
This strategy recommends the following process to formally review the CMOM Program elements on
a five year cycle:
1. Review the CMOM Program performance measures established in each service
area\measurement category as outlined in Chapter 2.
2. Determine whether any performance measures are missing, obsolete, or require modifications.
Review the measure from an effectiveness perspective (i.e., are the data collection and
tracking efforts worth the benefit to the program).
3. If no process exists for continual data collection, gather data required for evaluating the
program within each performance measure.
4. With input from the CMOM work team, review the goals and determine if changes are
necessary.
5. If the performance measure is used for an external comparison or benchmarking, review the
quality of the external data set to determine if this information is still applicable, up to date,
and appropriately defined for comparison.
6. Prepare the performance measure status report for inclusion in the CMOM Program summary
recommended under the management plan strategy described in Chapter 2. This report should
include all applicable internal trending and external comparison summaries, as appropriate.
The report will include, if necessary, a prioritized list of action items that will improve the
CMOM Program overall and the CMOM audit process.
7. Prepare a comment for each performance measure that provides an interpretation of the
program performance relative to the goal. The comment may include a recommendation to
change the goal, a change to the program such that the Village can attain the goal or
verification that the Village has attained the goal.
6.2.3. Acquire Benchmark Data
The Village will need benchmark data, reflecting the CMOM Program performance of similar
agencies, to evaluate the CMOM Program relative to industry standards. Under the CMOM Program
proposed in this document, the Village would develop a procedure to obtain this data, if it is
available.
The Director of Public Works would determine whether sharing certain CMOM Program-related data
with other organizations would benefit the program. If so, up to three partnering agencies would be
identified that are interested in sharing the needed performance data. These agencies would share
similar characteristics with the Village such that they would provide appropriate comparisons. Such
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characteristics could include the following list, but would be specific to the performance measure in
question:
Service population
Climate
System age
Presence of combined sewer area
Presence and extent of operation and maintenance (O&M) contracts
The DPW would establish the priorities for acquiring the remaining benchmarking data, based on the
data’s criticality to evaluating CMOM Program performance. Through the eCMAR program, WDNR
is gathering a substantial amount of benchmarking data from Wisconsin public sewer systems.
WDNR intends to eventually share this information for the purpose of comparing performance in a
number of areas, including:
Sewer cleaning and root removal
Flow monitoring
Smoke testing
Sewer line televising and manhole inspections
Manhole and sewer main rehabilitation
Private sewer inspections and I/I removal activities
6.2.4. Develop Five-Year Program Review Process

The five-year program audit is an in-depth evaluation of the Village’s CMOM performance and an
opportunity to structure the future direction of the program. The Village will need to establish the
process as part of the Program Audit Plan. A peer group of representatives from similar agencies
may facilitate this review. Village staff will need to establish the peer group prior to this review;
however, it would be ideal if the agencies were among those providing benchmarking data. Ideally,
the program audit would be completed and submitted six months prior to NPDES permit reissuance,
making the results useful in the permit drafting process.
6.2.5. Establish Responsibility for Periodic Program Audit
The DPW will be responsible for facilitating periodic audits of the Village’s CMOM Program.
6.3.0. Performance Measures
This strategy recommends the following performance measures to assess successful implementation
of the Program AP:
1. Perform program audit on a five-year cycle
2. Percent of specific activities audited during the cycle
3. Degree of satisfaction with benchmark data
4. Number of gaps closed per cycle.
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Chapter 7 - CMOM Program Implementation Strategy

This chapter presents the Village’s implementation plan for the CMOM strategies presented in
previous chapters. The implementation plan describes the timing of activities that are critical if the
USEPA promulgates the CMOM rules in their current draft form. The overall CMOM Program
schedule and actions will drive the timing of the activities.
In general, CMOM implementation will follow a cycle of assessing the status of activities,
developing strategies and tactics for improvement, implementation, and evaluation of performance.
As shown in Figure 7-1, this is a continuous cycle for the CMOM Program. With this Strategic Plan
the Village has finalized the goals and objectives for all aspects of the CMOM Program, and these
goals and objectives will be the focus for evaluation and implementation of the CMOM.
Figure 7-1. The CMOM Cycle
In December 2005, the Village entered into a Satellite Stipulation with WDNR. Among other items,
the Satellite Stipulation requires the Village to develop and implement a CMOM Program by June 30,
2009. With this Strategic Plan, the Village intends to complete the CMOM cycle through the tactics
phase no later than June 30, 2009, deadline in the Satellite Stipulation. The Village will complete the
activities outlined below by that date.
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7.1.0 Summary of Implementation Activities

Implementing the CMOM Program strategy will include the specific activities identified in Table 7-1.
These activities are identified as high, medium and low priorities. The Village will identify and
resolve these priority areas to ensure that their goals and strategies are met.
Table 7-1. CMOM Program Strategy Implementation Activities
Strategy Element Steps Priority
Management Plan 1. Brief Council/Board on CMOM High
Strategy
2. Assemble information to complete
High
Management Plan template
3. Draft Management Plan
High
4. Finalize Management Plan
High
O&M Plan 1. Review and enhance Inspection High/ongoing

Program as necessary (Sewers, and
Manholes)
High/ongoing
2. Review and enhance cleaning program
as necessary
3. Provide recommendations for High/ongoing
repair/replace/rehab on a regular basis
Medium
4. Review and enhance for FOG program
Overflow Response 1. Assemble information to complete ORP High
Plan template.
2. Train staff on ORP. High
3. Develop mock drills and schedule. High/ongoing
4. Establish inter-agency assistance Completed
agreements for improved ORP
response.
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Strategy Element Steps Priority

SECAP 1. Review Village design criteria related to To be determined if
system capacity. required
2. Evaluate Village’s conveyance system
using hydraulic analysis tools.
3. Perform any appropriate field
investigations
4. Evaluate system flows relative to
MMSD Peak Flow Performance
Standards.
5. Evaluate a wide range of capacity-
enhancement and peak flow reduction
measures
6. Develop a CIP list of capacity
enhancement projects
7. Evaluate the impact of inter-
municipality connection discharges
8. Produce a SECAP document
Communication 1. Develop the CP. High

Plan 2. Assign staff responsibilities for the CP.
3. Distribute the CP to all appropriate
stakeholders.
Audit Plan 1. Develop review and program change High

procedures.
2. Perform five-year audit of CMOM
Program.
High = Before June 30, 2009

Medium = By 2011
Low = By 2015
7.2.0. Documents to Be Prepared As Part of CMOM Program Implementation

The Village will develop a number of documents in the course of CMOM Program implementation.
The Village already has the majority of these programs documented and will need to compile these
and enhance as necessary. The following is a list of documents that would be necessary, at a
minimum:
1. Management Plan
2. Overflow Response Plan
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3. Communications Plan
4. Audit Plan
5. Annual CMOM Report
6. Five Year Audit Report
7. SECAP, if necessary
8. O&M Plan Operation and Maintenance procedures for the sewer collection system
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APPENDICES
Appendix A – CMOM Documents Reviewed
Appendix B – Summary of Readiness Review Findings
Appendix C – Summary of General Reporting Requirements for SSO Events
Appendix D – Example ORP Outline
Appendix E – MMSD SECAP Outline Template
Appendix F – MMSD CMOM Program Communications Plan Outline Template
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Appendices
MMSD Satellite Municipality CMOM Readiness

Review and Strategy
Contract M03008P02
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Appendix A
CMOM Documents Reviewed

1. Inspection reports (sewers and manholes)
2. Maintenance records
3. Maps including as-built drawings
4. Capital Improvement Plan
5. Budgets
6. Safety Manual
7. Position Descriptions
8. Bypass reports
9. Emergency Response Plan
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Appendix B
Summary of Readiness Review Findings
Prior to developing this CMOM Strategic Plan, a CMOM Readiness Review Report was prepared for the Village of Whitefish
Bay. The findings of the Readiness Review, expressed as Opportunities for Improvement, are summarized in the table below.
The Village of Whitefish Bay reviewed each of these opportunities, established a strategy to achieve the eventual goal, and
selected a priority according to the following timeline:
• High = Before June 30, 2009

• Medium = By 2011
• Low = By 2015
Business Process Current Strategy to

Timing Service Area Goal
Area Status Address Issue
High Collection System Policy – Mission Mission Statement To be Developed Documented in High Defined
Statement CMOM Management
Strategy
High Collection System Policy – Quality To Be Updated Documented in High Defined

Strategic Goals Related to Customer CMOM Program
Service Strategy
High Collection System Policy – Quantity To Be Updated Documented in High Defined

Service Strategy
High Collection System Policy – Reliability To Be Updated Documented in High Defined

Service Strategy
High Collection System Policy – Responsiveness To Be Updated Documented in High Defined

Service Strategy
High Collection System Policy – Environmental Acceptability To Be Updated Documented in High Defined
Service Strategy
High Policy – Strategic Goals to Achieve CMOM Regulations To Be Developed Documented in High Defined
Regulatory Compliance CMOM Program
Strategy
High Policy – Strategic Goals to Achieve Compliance Orders or To Be Developed Documented in High Defined
Regulatory Compliance Decrees CMOM Program
Strategy
High Policy – Strategic Goals for Work Efficiency To Be Updated Documented in High Defined
Management CMOM Program
Strategy
High Policy – Strategic Goals for Work Prioritization To Be Updated Documented in High Defined
Strategy
High Policy – Strategic Goals for Work Safety To Be Updated Documented in High Defined
Strategy
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High Policy – Strategic Goals for Work Quality of Life To Be Updated Documented in High Defined
Strategy
High Maintenance – Gravity System Maintenance Prioritization To Be Updated To be documented in High Defined
Preventive updated O&M
Manual.
Medium Maintenance – Gravity System FOG Program To Be Developed To be documented in High Defined
Preventive updated O&M
Manual.
Medium Maintenance – Gravity System Root Control To be Updated To be documented in High Defined
Preventive the updated O&M
Manual
High Maintenance– Gravity System Manholes To be updated To be documented in High Defined

Preventive the updated O&M
Manual
High Maintenance – Right-of-Ways Maintenance Prioritization To Be Updated To be documented in High Defined

updated O&M
Manual
High Maintenance – Right-of-Ways Residential Easements and To Be Updated To be documented in High Defined
Right-of-Ways updated O&M
Manual
High Maintenance - Emergency Program To Be Updated To be documented in High Defined

updated O&M
Manual
Low Operations – Corrosion Control Corrosion Control Program To Be Developed To be documented in High Defined
updated O&M
Manual
Medium Operations – Flow Monitoring Gravity Systems To Be Developed To be documented in High Defined
updated O&M
Manual
Medium Technical – Engineering Construction Inspection To Be Updated To be documented in High Defined

Management Plan.
Medium Technical – Engineering Condition Assessment - To Be Updated To be documented in High Defined

Smoke Testing Management Plan.
Medium Technical – Engineering Condition Assessment - To Be Updated To be documented in High Defined

Dyed Water Flooding Management Plan.
High Technical – Engineering Condition Assessment - To Be Updated To be documented in High Defined

CCTV Management Plan.
High Technical – Engineering Condition Assessment - To Be Updated To be documented in High Defined

Manholes Management Plan.
Medium Technical – Engineering Condition Assessment – To Be Updated To be documented in High Defined

Service Laterals Management Plan.
High Technical – Engineering Rehabilitation/Replacement To Be Updated To be documented in High Defined

Gravity Line – Criteria Management Plan.
High Technical – Engineering Rehabilitation/Replacement To Be Updated To be documented in High Defined

Manholes – Criteria Management Plan.
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High Technical – Engineering Capacity Assurance - To Be Developed To be documented in High Defined
Definition of Adequate Management Plan.
Capacity
Medium Technical – Engineering Capacity Assurance Tools – To Be Updated To be documented in High Defined
Flow Monitoring Management Plan.
Low Technical – Engineering Capacity Assurance Tools - To Be Updated To be documented in High Defined
Modeling Management Plan.
Medium Technical – Engineering Capacity Assurance Tools – To Be Updated To be documented in High Defined
Rules of Thumb Management Plan.
High Technical Support Function – Overflow Reporting, To Be Updated To be documented in High Defined
Information Management Notification, and Record the Overflow
Keeping - Regulatory Response Plan.
Agencies
High Technical Support Function – Overflow Reporting, To Be Updated To be documented in High Defined
Information Management Notification, and Record the Overflow
Keeping - Affected Agencies Response Plan.
and Public
High Technical Support Function – Maintenance To Be Updated To be documented in High Defined
Information Management the O&M Plan
High Technical Support Function – Operation To Be Updated To be documented in High Defined

Information Management the O&M Plan
High Technical Support Function – Information Management - To Be Updated To be documented in High Defined
Information Management Complaints Management Plan.
Medium Technical Support Function – System wide Information To be Updated To be documented in High Defined
Information Management Coordination to Support Management Plan.
Management
High Technical Support Function – Planning Process - Steps and To Be Updated To be documented in High Defined
Contingency Planning Tasks the Overflow
Response Plan.
High Technical Support Function – Planning Process - Public To Be Updated To be documented in High Defined
Contingency Planning Notification the Overflow
Response Plan.
High Technical Support Function – Planning Process - To Be Updated To be documented in High Defined
Contingency Planning Emergency Flow Control the Overflow
Response Plan.
Medium Technical Support Function – Fats, Oils, and Grease To Be Developed To be documented in High Defined
Source Control Control - Permitting Management Plan.
Medium Technical Support Function – Fats, Oils, and Grease Control To Be Developed To be documented in High Defined
Source Control - Inspection Management Plan.
Source Control - Enforcement Management Plan.
Source Control – Compliance Assistance Management Plan.
Source Control – Public Education Management Plan.
Medium Technical Support Function – Fats, Oils, and Grease To Be Developed To be documented in High Defined
Source Control Control – Performance Management Plan.
Measures
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Medium Technical Support Function – Legal Sewer Use Ordinance To Be Updated To be documented in High Defined
Support Management Plan.
Medium Technical Support Function – Legal Fats, Oils, and Grease To Be Developed To be documented in High Defined
Support Control Ordinance Management Plan.
Medium Technical Support Function – Legal Inter-Municipal Agreements To Be Updated To be documented in High Defined
High Technical Support Function – Legal Service Laterals To Be Updated To be documented in High Defined
High Administrative Support Function – Human Resources – Training To Be Updated To be documented in High Defined
Human Resources – Technical, Skills and Management Plan.
Safety
High Administrative Support Function – Human Resources - Safety To Be Updated To be documented in High Defined
Human Resources Program - Performance Management Plan.
Measures
Medium Administrative Support Function – Tools Purchase and To be Developed To be documented in High Defined
Procurement Inventory Management Plan.
Medium Administrative Support Function – Spare Parts Purchase and To be Developed To be documented in High Defined
Medium Administrative Support Function – Supplies Purchase and To be Developed To be documented in High Defined
Medium Administrative Support Function - Rate Analysis To Be Updated To be documented in High Defined
Financial Management Plan.
Medium Administrative Support Function - Life Cycle Cost Analysis To Be Developed To be documented in High Defined
Financial Management Plan.
High Administrative Support Function – Complaint Management To Be Updated To be documented in High Defined
Customer Service Management Plan.
High Administrative Support Function – Public Information To Be Developed To be documented in High Defined
High Administrative Support Function – Public Education To Be Developed To be documented in High Defined
Medium Non-Core Business Functions Storm Drainage, Streets and To Be Developed To be documented in High Defined
Highways, Parks and Management Plan.
Recreation and other
Departments
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Appendix C
Summary of General Reporting Requirements for SSO Events
This summary outlines the similarities and differences in reporting procedures and requirements for sanitary sewer overflow
(SSO) events. Not included in this summary are monitoring reporting procedures and non-compliance reporting requirements
resulting from monitoring activities.
Unscheduled sanitary sewer overflow events

Reporting procedures and requirements for SSO include the following:
Within 24 hours of overflow initiation, contact (fax, voicemail, e-mail) WDNR's Southeast Regional Office.
Within 24 hours of a ¾-inch 24-hour precipitation event, each permanently installed overflow structure must be inspected
to look for evidence of an SSO.
Within 5 days of conclusion of the SSO event, submit a written report to WDNR's Southeast Regional Office. See
required report information below in Section A.
An annual report is required to summarize the status of the collection system and any SSOs that occurred during the year.
See required report information below in Section B.
If the SSO potentially impacts a drinking water intake in Lake Michigan, Lake Superior, or Lake Winnebago, the
permittee must notify the owner of the intake as soon as possible.
If monitoring determines that certain types of permit non-compliance events have occurred, then a phone call shall be
made within 24 hours after becoming aware of the noncompliance to WDNR’s Southeast Regional Office, followed
by a written report submitted within 5 days. These procedures are discussed below in Section C.
A. Requirements for 5-day written reports:

1) SSOs
SSO report should include the following information:
Reason the SSO occurred, or explanation of other contributing circumstances that resulted in the overflow event. If the
SSO is associated with wet weather, provide data on the amount and duration of the rainfall or snow melt for each
separate event.
Date the SSO occurred.
Location where the SSO occurred.
Duration of the SSO and estimated wastewater volume discharged.
Steps taken or the proposed corrective action planned to prevent similar future occurrences.
Any other information the permittee believes is relevant.
B. Requirements for annual reports:

1) SSOs
A Compliance Maintenance Annual Report (CMAR) is required to be submitted by the permittee. The CMAR should
describe wastewater management activities, physical conditions, as well as performance of the treatment works during the
year. Information that should be included in the CMAR can be found in NR 208.04(5) of the Wisconsin Administrative Code.
Each section of the report is assigned a point score and grade based on information and data collected during the year. The
scores are used to determine the applicable grade and response action as outlined in NR 208.05(2).
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C. Noncompliance Notification Requirements:

The permittee shall report the following types of noncompliance by a telephone call to WDNR’s Southeast Regional Office
within 24 hours after becoming aware of the noncompliance:
any noncompliance which may endanger public health or the environment;
any violation of an effluent limitation resulting from an unanticipated bypass;
any violation of an effluent limitation resulting from an upset; and
any violation of a maximum discharge limitation for any of the pollutants listed by WDNR in the WPDES permit, either
for effluent or sludge.
A written report describing the noncompliance shall also be submitted to the WDNR's Southeast Regional Office within 5
days after the permittee becomes aware of the noncompliance. On a case-by-case basis, the WDNR may waive the
requirement for submittal of a written report within 5 days and instruct the permittee to submit the written report with the next
regularly scheduled monitoring report. In either case, the written report shall contain a description of the noncompliance and
its cause; the period of noncompliance, including exact dates and times; the steps taken or planned to reduce, eliminate and
prevent reoccurrence of the noncompliance; and if the noncompliance has not been corrected, the length of time it is expected
to continue.
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Appendix D
Example ORP Outline
Section I: Authority
Section II:General
A.Objectives
B.Organization of Plan
C.Sanitary Sewer Overflow (SSO) Tracking
Section III: Overflow Response Procedure
A.Receipt of Information Regarding an SSO
a. Telephone Overflow Reports
b. Pump Station Reports
c. Municipality Staff Overflow Reports
B.Overflow Confirmation
C.Dispatch of Appropriate Crews to Site of SSO
a. Dispatching Crews
b. Crew instructions and work orders
c. Additional Resources
d. Preliminary assessment of damage to private and public property
e. Field supervision and inspection
f. Coordination with hazardous material response
D.Overflow Correction, Containment and Clean-Up
a. Responsibilities of response crew upon arrival
b. Initial measures for containment
c. Additional measures under potentially prolonged overflow conditions
d. Clean-up
E. Overflow Report
a. Cause of overflow
b. Location of overflow
c. Approximate start time of overflow
d. Stop time of overflow
e. Estimated volume of overflow
f. Proposed corrective action to prevent future occurrences
g. Precipitation data (if wet weather overflow)
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h. Other relevant information

F. Customer Satisfaction
Section IV: Public Advisory Procedure
A.Temporary Signage
B.Other Public Notification
Section V: Media Notification Procedure
A.Public Information Office Contacts for After Hours or Weekend Overflows
Section VI: Distribution and Maintenance of ORP
A.Submittal and Availability of ORP
B.Review and Update of ORP
C. Practical Resources
D. Training
Appendix A: Sample Sewage Overflow Report
Appendix B: Document Updates
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Appendix E
MMSD SECAP Outline Template
EXECUTIVE SUMMARY
1. INTRODUCTION
1.2 Background
1.3 Purpose
2. REGULATORY FRAMEWORK
2.1 Proposed CMOM Regulations
2.2 SECAP Requirements
2.3 Interlocal Agreements
3.4.1 MMSD
3.4.1 Other Agencies
3. SYSTEM EVALUATION
3.1 Existing Conditions
3.1.1 Wastewater Collection System
3.1.1.1 Conveyance
3.1.1.1.1 Trunk and Interceptor Sewers
3.1.1.1.2 Collectors
3.1.1.2 Pumping Stations
3.1.1.3 System Overflows
3.1.1.3.1 Combined Sewer Overflows (CSO)
3.1.1.3.2 Sanitary System Overflows (SSO)
3.1.1.4 Dry- and Wet-Weather System Operating Strategies
3.1.1.5 Flow Monitoring
3.1.1.6 LSSES Findings
3.1.2 Observed Hydraulic Deficiencies
3.1.2.1 Local and MMSD Definitions
3.1.2.1.1 Hydraulic Deficiencies
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3.1.2.1.2 Level of Service

3.1.2.2 Trunk and Interceptor Sewers
3.1.2.3 Collector Sewers
3.1.2.4 Pump Stations
3.1.2.5 System Overflows
3.1.2.5.1 Combined Sewer Overflows (CSO)
3.1.2.5.2 Sanitary System Overflows (SSO)
3.1.2.6 Building Lateral Back-ups
3.1.3 Current and Pending Capital Improvement Projects (CIP)
3.1.3.1 Conveyance
3.1.3.2 Pumping Stations
3.1.3.3 Overflow Reduction (Storage)
3.1.3.4 I/I Reduction and Related System Improvements Projects
3.1.4 System Hydraulic Analysis Under Current Conditions
3.1.4.1 Description of Model and Capabilities
3.1.4.2 Hydraulic Deficiencies Under Current Conditions
3.2 Future Conditions
3.2.1 Wastewater Flow Projections
3.2.1.1 Year 2020 Conditions (Planning)
3.2.1.2 Full Build-Out Conditions
3.2.2 System Hydraulic Analysis Under Future Conditions
3.2.2.1 Description of Model Changes Under Future Conditions
3.2.2.2 Hydraulic Deficiencies Under Future Conditions
3.2.2.2.1 Trunk and Interceptor Sewers
3.2.2.2.2 Collector Sewers
3.2.2.2.3 Overflows
3.2.2.2.4 Building lateral backups
3.2.2.2.5 Pumping Stations
4. CAPACITY ASSURANCE PLAN

4.1 Development of Alternatives
4.1.1 Public and Private I/I Reduction
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4.1.2 Rehabilitation and Reconstruction

4.1.3 Capacity Enhancement
4.1.4 Pumping Station Upgrades/Improvements
4.1.5 Storage/Detention Basins
4.1.6 Real-Time Control (RTC)/System Optimization
4.1.7 Other Measures
4.2 Evaluation of Alternatives
4.2.1 Establishment of Evaluation Criteria
4.2.2 Evaluation and Comparative Ranking
4.2.3 Discussion of Results
4.2.4 Recommended Mitigation Program
4.3 Recommended Cap
4.3.1 Overview of CAP
4.3.2 Description of Components
4.3.2.1 CIP
4.3.2.2 I/I Reduction and Related System Improvements
4.3.2.3 Operational Modifications
4.3.3 MMSD versus Satellite Community Responsibilities
4.3.4 Program Phasing and Schedule
4.3.5 Required SECAP Updates
APPENDICES
A. Interlocal Agreements
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Appendix F
MMSD CMOM Program Communication Plan Outline Template
CMOM Program Communication and Audit Plan Outline
I. Communication Plan
a. Introduction
i. Objectives of the CMOM Program
ii. Organization of the Communication Plan
b. Publications produced by the CMOM Program
c. Presentations and Briefings Made Regarding the CMOM Program
i. Municipality Staff
ii. Elected Board
iii. Technical Advisory Team and/or MMSD staff
iv. Wisconsin Department of Natural Resources
v. Other Stakeholder Groups
d. Regulatory Reporting
i. Cyclic
ii. Incident-Driven
e. CMOM Program Communications
i. Information Management System
ii. Benchmark Program
iii. Service Area Knowledge-Sharing Program
iv. CMOM Program Materials
f. Communication Program Performance Measures
g. Distribution and Maintenance of Plan
i. Staffing responsibility for preparation of plan updates
ii. Plan recipients
II. Program Audit Plan
a. Introduction/ Summary of CMOM Program
b. Summary of Program Accomplishments for Year
c. Analysis of Performance Measures Results
d. Comparison of Outcomes
i. Target levels
ii. Actual results
iii. Previous year results
e. Discussion of Results
f. Summary of Future Actions and Initiatives for Next Annual Cycle
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Appendix D
APPENDIX D
OVERFLOW RESPONSE PLAN
1. PURPOSE
The Overflow Response Plan is to ensure that every confirmed sanitary sewer overflow
(SSO) is adequately addressed to ensure that the effects of the overflow are minimized
with respect to impacts to public health and adverse effects on beneficial uses and water
quality of surface waters and customer service. This is required under s.283.55 (1)(dm)
Wisconsin Statues and in accordance with the WPDES permit. This is accomplished by:
• Immediate response to the SSO
• Minimize the effects of the SSO
• Provide containment and proper clean-up of the overflow
• Determining the cause of the SSO
2. BACKGROUND
The Village is committed to eliminate preventable Sanitary Sewer Overflows (SSOs) in

their collection system. This plan will provide procedures to respond to the SSOs. The
CMOM Plan requires an Overflow Response Plan (ORP). The ORP includes provisions
to ensure safety and public health are protected and notification and reporting is made to
the Wisconsin DNR and other agencies as required. Notification contact numbers can be
found in Table D-2.
The primary objective of the ORP is to protect public health and the environment, to
satisfy regulatory agencies and discharge permit conditions which address procedures
for managing sewer overflows, and minimize risk of enforcement actions against the
Village.
The ORP presents a strategy for the Village to mobilize labor, materials, tools and
equipment to correct or repair any condition which may cause or contribute to an
unpermitted discharge. The major components of the ORP are:
1. Identification of known or potential overflow sites

2. Receipt of Information regarding a potential SSO
3. Dispatch
4. Overflow Mitigation, Containment and Cleanup
5. Notification and Documentation
6. Root Cause Failure Analysis
Additional objectives of the ORP are as follows:

• Protect collection system personnel and wastewater treatment plant;
Overflow Response SOP_WFB_V2

November 30th, 2009 Page 1 of 13
APPENDIX D
• Protect the collection system, wastewater treatment facilities, and all

appurtenances; and
• Protect private and public property beyond the collection and treatment
facilities.
3. Identification of Overflow Sites
There are fourteen gravity overflow sites and two monitored sites in the Village of
Whitefish Bay as listed in Table D-1. Some overflow sites have a valve that is normally
CLOSED. To prevent wastewater from backing up into basements and creating an
immediate health hazard, the valves may be opened to flow to a storm sewer. These
sites have specific procedures to respond to and document overflows. This procedure
can be found in Appendix F, Wet Weather Procedure SOP.
4. Receipt of Information Regarding an SSO
An overflow may be detected by Village employees or by others. The Village is

responsible to respond to any calls or reports of a potential SSO and to provide
immediate response to investigate and/or correct reported sewer overflows.
All calls are routed to the Village Hall during work hours and to the police department
after hours. All calls are documented using a Public Works Service Request Form. The
person taking the call will contact the foreman to address the problem. See Appendix E
for the form. The following items should be included:
• Time and date call was received
• Callers name and phone number
• Time that the potential overflow was noticed
• Specific location of the problem
• Description of the problem and observations
• Other information that could assist the Village to quickly
location, assess and correct the problem. UNTIL FIELD
The Village also has a procedure to discuss sewer back-up VERIFIED, THE
protocols. This procedure can be found in Figure D-1. REPORT OF A
POSSIBLE SPILL WILL
5. Dispatch NOT BE REFERRED
TO AS A “SEWER
a. Upon receipt of a notification that there could be an OVERFLOW.”
overflow OR in the event that heavy rains are predicted,
the DPW will dispatch a designated employee to
investigate the problem. This person shall investigate

APPENDIX D
and confirm if there is an SSO. See Wet Weather SOP in Appendix F to respond
to the specific sites with overflows.
b. If a SSO is confirmed then it must be reported. See Item No. 7 - Notifications for
detailed requirements. The DNR must be notified verbally or electronically within
24 hours and in writing within 5 days.
c. Determine the cause of the overflow, (e.g. high flows, sewer line blockage, or
sewer line break).
d. Identify and request, if necessary, assistance or additional resources to correct the
overflow or to assist in the determination of its cause. See emergency contractor
contact numbers in Table D-3.
e. Estimate quantities of flow for the overflow.
f. Estimate overflow quantities based on time and volume
• Note date and time start_______________________
• Note date and time stopped____________________
• Overflow –circle approximate flow depth ¼ pipe ½ pipe ¾ pipe or full pipe
• Or if notified and it appears that this overflow has been occurring for a while
– estimate start time
g. Document time when SSO is contained.
h. All overflow quantities must be reported to the DNR.
i. If using a portable pump document actual start and stop time. Document pump
capacity and calculate gallons pumped.
Gallons = pump time (minutes) x pump capacity in gallons per minutes (gpm)
6. Overflow Mitigation, Containment and Cleanup
The following procedure will be followed to clean-up the SSO.

a. Identify the destination of the overflow (storm sewer, street, specific location, river,
lake)
b. Secure the area to prevent contact by members of the public until the SSO has
been addressed and cleaned up.
c. Take immediate steps to stop or minimize the impact of the SSO,
i. Relieve Village sewer blockage by cleaning the sewer

APPENDIX D
ii. Install portable pump at the manhole and pump to a storm sewer or another
sewer manhole if possible. See Wet Weather SOP in Appendix f for more
details.
iii. Open Overflow Valves for the overflow sites as noted in Table D-1. This
can only be done with the permission of the Village Manager or her or his
designee.
iv. Call emergency contractors or other municipalities for assistance as
necessary. See Table D-3 and D-4 for contact information.
d. Request additional personnel, materials, supplies, or equipment that will expedite
and minimize the impact of the overflow
e. Cleanup –
i. Secure the site – route traffic around if necessary.
ii. Take photos of the SSO
iii. Where practical thoroughly flush the area and clean any sewerage or wash-
down water. Solids and debris may be flushed, swept, picked up or
transported for proper disposal. Liquids may be discharged to the sanitary
sewer.
f. Notification to stakeholders needs to be completed for all SSOs. See Table D-2
for Notification Contacts.
7. Notification and Documentation

• Village Personnel
• Wisconsin DNR
• Water Utilities
• District
• Public Notification
• Others

APPENDIX D
a. Village
All overflows shall be reported immediately to the Village Manager and the
Director of Public Works.
b. DNR Notification
• Notify the DNR within 24 hours of initiation or SSO(verbal)
• Notify the DNR within 5 days 24 hours of initiation or SSO(written)
If an overflow is verified the Village shall notify the DNR within 24 hours of
initiation or SSO occurrence by telephoning the wastewater staff in the regional
office as soon as reasonably possible. If staff are unavailable, the use of fax, e-
mail, or voicemail is acceptable. It is recommended that if possible, an email is
sent for documentation.
Primary DNR contact is Theodore Bosch at (414) 263-8623, fax at (414) 263-
8716, or by e-mail at Theodore.bosch@wisconsin.gov. For the written reporting
requirements the DNR recommends the permittee submit WDNR Form 3400-184
“Sanitary Sewer Overflow or Bypass Notification Summary Form”. This form is
available in Appendix E and is available for download on the DNR site.
http://dnr.wi.gov/org/water/wm/WW/form3400184.htm/
Within 5 days of conclusion of the bypass or overflow occurrence, report the

following information to the DNR in writing:
• Reason the overflow occurred, or explanation of other contributing

circumstances that resulted in the overflow event. If the overflow is
associated with wet weather, provide data on the amount and duration of the
rainfall or snow melt for each separate event.
• Date the overflow occurred.
• Location where overflow occurred.
• Duration of the overflow and estimated wastewater volume discharged.
• Steps taken or the proposed corrective action planned to prevent similar
future occurrences.
• Receiving water for overflow
• Any other information the permittee believes is relevant.
• Forward a copy of the written report to the District.

APPENDIX D
c. Water Utility Notification

The Village is required to notify the water utilities that might be impacted by the
SSO to protect their drinking water sources. North Shore Water Utility must be
immediately notified since
d. District
The Village is required to notify the Milwaukee Metropolitan Sewerage District
(District) of all SSOs. Forward a copy of the DNR form to the District. .
e. Public Notification
As appropriate, the public will be notified. This may include a posting on the
Village website identifying all pertinent information.
f. Other Notifications
• All overflows that impact other municipalities will be notified. If an overflow
impacts a downstream municipality as identified on the attached map, notify
the applicable downstream municipality. The other municipalities that could
be affected are Shorewood, Fox Point and Glendale.
• The North Shore Public Health Department should be notified if an overflow
occurs.
8. Root Cause Failure Analysis

All overflows need to be investigated to determine the cause. A root cause failure
analysis form is included in the Appendix E to assist in determining the cause of the
overflow. The analysis should also include measures taken to prevent future SSOs.
9. Safety
Refer to the Village Safety Program for general safety procedures related to sanitary
sewer overflows.
10. References
a. Village Safety Program
b. Appendix E – Forms
• Root Cause Analysis Form
• Public Works Service Request Form
c. Appendix F – Wet Weather Procedure SOP

APPENDIX D
SOP DOCUMENT TRACKING

Document Name: Overflow Response Plan SOP_WFB_V2.doc
Author: Joan B. Hawley/Superior Engineering
Approved: June 30th, 2009
Issue Date: June 30th, 2009
Revised By: Joan B. Hawley Date: November 30th, 2009 Version 2
Revised By: Date:

APPENDIX D
Table D-1 Village of Whitefish Bay Sanitary Sewer Overflow Points
Manhole
Circle Drive (near public walk Storm Sewer on Circle, to Lake Michigan (Silver Spring
WB 16 to Marlborough) Overflow Site Valved Outfall)
Storm Sewer on Lake Dr, to Lake Michigan (Silver Spring
WB 20 Lake Drive @ Lake View Overflow Site Duck Bill Valve Outfall
Storm sewer on Montclair, to Lake Michigan (outfall n/o
WB 1 Montclair & Kent Overflow Site Gravity Pipe Klode Park)
WB 6 Montclair & Bayridge Overflow Site Gravity Pipe Klode Park)
WB 7 Montclair & Santa Monica Overflow Site Gravity Pipe Klode Park)
WB 9 Montclair &Berkeley Overflow Site Gravity Pipe Klode Park)
WB14 Montclair & Lake Dr Overflow Site Gravity Pipe Klode Park)
Storm sewer on Monrovia, to Lake Michigan (outfall n/o
WB 13 Monrovia & Lake Overflow Site Valved Klode Park)
Storm Sewer on Lancaster, to Milwaukee River
WB 19 Diversey & Lancaster Overflow Site Gravity Pipe @Estabrook Park
Storm Sewer on Hampton, to Milwaukee River
WB 26 Sheffield & Hampton Overflow Site Valved @Estabrook Park
Storm Sewer on Newhall, to Lake Michigan (Buckley Park
WB 18 Newhall & Fairmount Overflow Site Gravity Pipe Outfall)
Storm Sewer on Lake Dr, to Lake Michigan (Buckley Park
WB 23 Oakland & Lake Dr Overflow Site Gravity Pipe Outfall)
Storm Sewer on Newhall, to Lake Michigan (Buckley Park
MH 91 Newhall & Chateau Overflow Site Gravity Pipe Outfall)
Storm Sewer on Idlewild to Lake Michigan (Silver Spring
MH 88 Lexington & Idlewild Monitored Site Portable Pump Outfall)

APPENDIX D
Table D-2
Emergency Contact Numbers
Description Name Number Email Notification Time
Village
Village Manager James (414) 962-6690 manager@wfbvillage.org Immediately
Grassman
Director of Public Works Daniel Naze (414) 962-6690 D.naze@wfbvillage.org Immediately
Assistant Engineer Aaron Jahncke (414) 962-6690 a.jahncke@wfbvillage.org
Superintendent Kevin Kaegi (414) 962-6690
Police – Non-Emergency (414) 962-4619

North Shore Health Dept Jamie Berg (414) 847-2713
or 271-2980
District Debra Jensen (414) 225-2143 djensen@mmsd.com 5 days
District Pete Topczewski (414) 225-2176 ptopczewski@mmsd.com 5 days
MMSD Contract Operator Veolia Water (414) 282-7200 5 days
or if busy (414)
747-3873
Wisconsin DNR Ted Bosch (414) 263-8623 Theodore.bosch@wiconsin. 24 hours/5 days
gov
Water Departments
Milwaukee Water Works (414) 286-3710 waterwebc@milwaukee.gov Notify within 12 hours
North Shore Water Eric Kiefer (414) 963-0160 ekiefer@northshorewc.com Notify immediately

APPENDIX D
Table D-3
Emergency Contactor Numbers
NAME ADDRESS PHONE SERVICES PERFORMED
Village Of Shorewood (414) 847-2650 Sewer blockages, cleaning, emergency

support
Visu-Sewer W230 N4855 Betker (262) 695-2340 Sewer blockages, overflow cleanup,
Road inspections, emergency sewer lining
Pewaukee, WI work.
Superexcavators N59-W14601 Boblink, Excavating, emergency sewer repair
Menomonee Falls
Willkomm Exavating & 17108 County Line (262) 878-0877 Office Excavating, emergency sewer repair
Grading, Inc Road, Union Grove Emergency (262) 770-
53182 1386
Globe Contractors Inc N50 W23076 Betker (414) 828-8972 cell Excavating, emergency sewer repair
Road OFFICE - (262) 246-0600 dano@globecontractors.com
Pewaukee, WI 53072 828-8978
Kenway Sewer & Drain (414) 384 7050 Residential sewer blockages and catch
Cleaning basin cleaning

APPENDIX D
Table D-3
Emergency Contractor Contacts (Continued)
NAME ADDRESS PHONE SERVICES PERFORMED
WASTE HAULERS
Veolia ES Special Services N104 W13275 Donges (262) 236-8130 Chemical spills, cleanup of hazardous
Bay materials and wastewater hauling and disposal
(Industrial services)
Advance Waste Services 1126 S 70th #N408B (414) 475-3100 Emergency response for cleanup of hazardous
West Allis WI materials and wastewater hauling and disposal
Future Environmental 3240 West Elm Road Emergency response for cleanup of hazardous
Franklin WI (414) 7619421 materials and wastewater hauling and
disposal. Oil disposal.
North Shore Environmental N117 W18493 Fulton (262) 255-4468 Emergency spill response for hazardous
Drive materials and wastewater hauling.
Germantown, WI

APPENDIX D
Table D-4
Mutual Aid Emergency Contact Numbers
Municipality Name Title Number Email
Bayside Andy Pederson Village Manager (414) 351-8811 apederson@bayside-wi.gov
Brown Deer Larry Neitzel Director of Public Works (414) 357-0120 vbdpwlarry@sbcglobal.net
Fox Point Scott Brandmeier Director of Public Works (414) 351-8900 sbrandmeier@vil.fox-point.wi.us
Glendale Dave Eastman Director of Public Works (414) 228-1746 d.eastman@glendale-wi.org
River Hills Kurt Frederickson Superintendent of Public (414) 352-0080 lfredrickson@vil.river-hills.wi.us
Works
Shorewood Leeann Butschlick Director of Public Works (414) 847-2650 lbutschlick@villageofshorewood.org

APPENDIX D
Figure D-1

Appendix E
State of Wisconsin Notice of Intent to Apply for Coverage Under MS4 General Permit
Department of Natural Resources
dnr.wi.gov
Form 3400-191 (R 3/06) Page 1
Notice: This application is authorized by s. 283.37, Wis. Stats., and chs. NR 151 and 216, Wis. Adm. Code. Personally identifiable information on this
form may be used for other program purposes and may be made available to requestors under Wisconsin's Public Records laws and be posted on the
Department’s internet site.
Instructions: Complete the following for all permit applications. If additional space is needed to respond to a question, attach
additional pages. Provide descriptions below that explain the program activities that you expect to develop and implement to comply
with the Municipal Separate Storm Sewer System (MS4) general permit (http://dnr.wi.gov/org/water/wm/nps/stormwater/muni.htm).
Section 3 of the MS4 general permit contains the compliance schedules that direct when the individual program activities need to be
developed and submitted to the Department for review. The detailed programs that are developed and submitted to the Department for
review may deviate from the program activities described below if necessary. The descriptions provided below are necessary for the
Department to verify that the municipality’s program activities comply with the permit.
Section I: Applicant Information

Name of Municipality
Mailing Address City State Postal Code
County(s) in which Applicant is located Type of Municipality: (check one)

County City Village Town Other (specify)
Section II: Local Contact Information (check one):

Name of Municipal Contact Person Title
Mailing Address City State Postal Code
E-mail address Telephone Number (include area code) Fax Number (include area code)
Section III: Water Quality Concerns

Yes No
Does any part of the MS4 discharge to an outstanding resource water (ORW) or exceptional resource
water (ERW) listed under s. NR 102.10 or 102.11, Wis. Adm. Code? (An unofficial list of ORWs and ERWs may
be found on the Department’s Internet site at: http://dnr.wi.gov/org/water/wm/wqs/ )
Does any part of the MS4 discharge to an impaired waterbody listed in accordance with section 303(d)(1)
of the federal Clean Water Act, 33 USC § 1313(d)(1)(C)? (A list of Wisconsin impaired waterbodies may be found on
the Department’s Internet site at: http://dnr.wi.gov/org/water/wm/wqs/303d/303d.html )
Section IV: Area and Population Within the MS4
Yes No
Is the MS4 within an “Urbanized Area” as defined by U.S. EPA? (See http://www.epa.gov/npdes/pubs/fact2-2.pdf)
If no, skip the rest of this section and continue to Section V. If yes, estimate the area served by and the population
within the MS4 in an Urbanized Area (UA).
(Urbanized Area maps are available on the EPA web site at: http://cfpub1.epa.gov/npdes/stormwater/urbanmaps.cfm)
Total municipal area (in square miles): Total municipal population (in year 2000):
MS4 service area within Urbanized Area (in square miles): Municipal population within Urbanized Area (in year 2000):
Section V: Potential Permit Exemption

Section NR 216.023, Wis. Adm. Code, allows certain MS4s that have less than 1000 people residing in
Yes No an urbanized area to be waived from having to obtain municipal storm water permit coverage.
Do you believe that the MS4 may be eligible for this potential exemption?
Notice of Intent to Apply for Coverage Under MS4 General Permit
Form 3400-191 (R 3/06) Page 2
Section VI: Summary of Municipal Storm Water Program Activities

Describe the programs or activities the municipality is doing or will do to comply with the requirements of the MS4
general permit. Attach additional pages if necessary.
A. Public Education and Outreach

Describe the public education and outreach program activities that the municipality will implement to comply with
section 2.1 of the MS4 general permit.
B. Public Involvement and Participation

Describe the public involvement and participation program activities that the municipality will promote to comply with
section 2.2 of the MS4 general permit.
C. Illicit Discharge Detection & Elimination

Describe the illicit discharge detection and elimination program authority and activities that the municipality will develop
and implement to comply with section 2.3 of the MS4 general permit.
D. Construction Site Pollution Control

Describe the construction site pollutant control program authority and activities that the municipality will develop and
implement to comply with section 2.4 of the MS4 general permit.
E. Post-Construction Site Storm Water Management

Describe the post-construction storm water management program authority and activities that the municipality will
develop and implement to comply with section 2.5 of the MS4 general permit.
F. Pollution Prevention
Describe the pollution prevention program activities that the municipality will implement to comply with section 2.6 of the
MS4 general permit.
Section VII: Certification

I hereby certify that I am an authorized representative of the municipality that is the subject of this application for
general permit coverage, and that the information provided is true and complete, to the best of my knowledge. I
understand that Wisconsin law provides severe penalties for submitting false information.
Authorized Representative Name Title
Signature Date Signed
E-mail address Telephone Number (include area code) Fax Number (include area code)
Return this completed form to:

Wisconsin Department of Natural Resources
Storm Water Program – WT/2
PO Box 7921
Madison, WI 53707-7921
State of Wisconsin Sanitary Sewer Overflow or Bypass
Department of Natural Resources
Notification Summary Report
Form 3400-184 (4/02) Page 1 of 2
Notice: Under s.283.55 (1)(dm), Wis. Stats., and in accordance with reporting requirements in your WPDES permit, all permittees shall provide the following
notices if an unscheduled sanitary sewer overflow or bypass occurs:
• Within 24 hours of the occurrence, notify the DNR regional wastewater staff by telephone (FAX, email or voice mail, if staff are unavailable).
• Within 5 days of the occurrence, provide a written report describing the overflow or bypass, including all information requested on this form. The permittee is
required to submit this form or other equivalent written notification to the DNR Regional Office.
Failure to notify the Department as specified may result in fines up to $10,000 for each day of violation [s. 283.91(2), Wis. Stats.].
Personally identifiable information will be used for program administration and will also be made available to requesters as required under Wisconsin Open
Records law [ss. 19.31 - 19.39, Wis. Stats.].
Instructions: Use this form to report all unscheduled sanitary sewer overflow or bypass occurrences. Attach additional information as necessary to explain
or document the overflow or bypass. For the purpose of this report, an overflow or bypass is defined as the discharge of untreated sewage from the sanitary
sewer collection system to a surface water and/or ground due to circumstances such as those identified by the check boxes in the overflow or bypass details
section of this form.
Use one form per occurrence. A single occurrence may be more than one day if the circumstance causing the overflow or bypass results in a discharge
duration more than 24-hours. If there is a stop and restart of the overflow or bypass within 24-hours, but it’s caused by the same circumstances, report it as one
occurrence. If the discharges are separated by more than 24 hours, they should be reported as separate occurrences.
Notification Information
Permittee (Municipality or Facility Name) Overflow or Bypass Reported To DNR
Date Time
am pm
Person Representing Permittee Who Contacted DNR DNR Office and Person Contacted
Overflow or Bypass Details

Date(s) and Duration of Overflow or Bypass Occurrence (complete a separate form for each occurrence)
Start Date Time (to nearest 15 minutes) End Date Time (to nearest 15 minutes)
am pm am pm
Duration of the overflow or bypass (hours and minutes) Estimated Volume of Wastewater Discharged (gallons)
Location of the Overflow or Bypass (complete a separate form for each discharge location)
Circumstances Causing the Overflow or Bypass (check all that apply)
Rain Power Outage Equipment Failure

Rain and Snow Melt Plugged Sewer Widespread Flooding
Snow Melt Broken Sewer Other (explain below)
Provide a narrative description to further explain why the overflow or bypass occurred. For example, describe what equipment failed, what caused the
power outage, or what plugged the sewer. Flooding should only be indicated as a cause if there is significant flooding that is caused by high river, stream, or
lake water levels, not just localized high water in the street.
Sanitary Sewer Overflow or Bypass
Notification Summary Report
Form 3400-184 (4/02) Page 2 of 2
Wet Weather Data (if applicable)

Document the weather conditions if it contributed to the cause of the overflow or bypass. An overflow or bypass may be caused by a series of short rain storms
or in combination with a snow melt. The wet weather data should include the cumulative amount of precipitation that caused the overflow or bypass.
Date(s) and Duration of Rainfall

Start Date Time (to nearest 15 minutes) End Date Time (to nearest 15 minutes)
am pm am pm
Amount of Rainfall (nearest rain gauge to 0.1 inch accuracy) Amount of Snow Melt (estimated inches melted)
Contributing Soil Conditions (saturated, frozen, soil type)
Where Did the Discharge from the Overflow or Bypass Go? (check all that apply)
Provide the name of the local receiving water that the wastewater enters, which could be a nearby stream, river, lake, or wetland. If discharge does not enter
directly into a surface water, but indirectly by way of a ditch or storm sewer, trace the path of the ditch or storm sewer to find the receiving water.
Runs on ground and absorbs into the soil.
Ditch. Name of surface water it drains to:
Storm sewer. Name of surface water it drains to:
Surface water direct discharge:
Other, describe:
Actions to Correct This Occurrence and Prevent Future Overflows or Bypasses

Describe what actions were taken to minimize the volume of wastewater discharged from the overflow or bypass reported on this form. Also describe what
actions are planned to prevent or minimize future overflows or bypasses. The WPDES permit prohibits overflows or bypasses, unless certain specified
conditions are met. If the permittee fails to operate and maintain the sewage collection system to prevent overflows and bypasses, they will be subject to
enforcement action.
Report Completed By
Authorized Representative Name (Print) Title
Authorized Representative Signature Date

5300 N. Marlborough Drive
Whitefish Bay, Wisconsin 53217
Phone: 414-962-6690
Fax: 414-962-5651
Whitefish Bay Resident:
The Whitefish Bay Sewer Department has recently televised the sanitary sewer
on your street and noticed that your sewer lateral has a heavy root growth that
could possibly create a sewer backup in your home in the future. The sewer lateral
is the underground pipe that serves your home only. The lateral from the sewer
main in the street to the building is the responsibility of the homeowner to maintain.
This notice serves as courtesy information only. If you have any questions you can
call me at the number above.
Daniel Naze, P.E.
Director of Public Works/Engineer

PUBLIC WORKS SERVICE REQUEST
Date Time am/pm

Call Taken By:
Name
Address
Phone Number
DESCRIPTION OF PROBLEM – SEWERS

Basement Backup Sewage or ponding water on Street
Manhole Cover Missing
OTHER – Describe
DESCRIPTION OF PROBLEM – STORM

Ponding water on street Catch basin blocked
other__________________________
Other – Describe______________________________________________________________________
OBSERVATIONS
CONTACTED: ASSIGNED TO
PROBLEM IDENTIFICATION
Confirmed Sanitary Sewer Overflow (SSO) YES –see Overflow Response Plan (ORP) No
Backup in private property lateral -- Manholes checked MH No.s
Backup due to blockage - public sewer -- Manholes checked MH No’s
Backup due to maintenance activities – Describe:
OTHER – LIST
PROBLEM RESOLUTION
Informed property owner of their obligations (private property lateral blockage)
Cleaned sewer – List MH numbers
Cleaned catchbasin List ID____________________________________________________________
Portable pumping required – Start time __________ End Time__________Pump gpm________
Estimated gallons pumped______________in gallons based on Pumping Estimated calculation
OTHER – LIST WORK COMPLETED
CLOSED OUT BY: _____________________________ DATE: _________________________
Public Works Service Request Form May 2009

ROOT CAUSE FAILURE ANALYSIS FORM
This form is to be used for overflows, sewer blockages, and other problematic areas.
Sewer Overflow - YES – see Overflow Response Plan - No
DESCRIPTION OF PROBLEM – SEWERS
Basement Backup Overflow at manhole MH # ______

Manhole Cover Missing MH #. _____ Sewage or ponding water on Street
Catch basin clogged CB # ____________
Overflow sites - see Wet Weather SOP
OTHER – Describe
PROBLEM IDENTIFICATION DATE:
Backup in private property lateral -- Manholes checked MH No.s _____

Backup due to blockage - public sewer -- Manholes checked MH No’s _____
Backup due to maintenance activities – Describe:
OTHER
PROBLEM RESOLUTION DATE:
Informed property owner of their obligations (private property lateral blockage)

Cleaned sewer – List MH numbers
OTHER – LIST WORK COMPLETED
FUTURE RECOMMENDATIONS
Televise Sewer MH____ to MH ____ 1
Clean Sewer MH ____ to MH ______
Smoke Test – Dyed Water Flooding
Inspect Private Property
OTHER – LIST
Completed by_________________________________ Date:_____________________
Root Cause Failure Analysis Form.doc

Page 1
VILLAGE OF WHITEFISH BAY SANITARY SEWER REPORT
2010 DAILY CLEANING
Work Performed By:
DATE BASIN RUN RUN TO ACTIVITY DISTANCE DEBRIS OBSERVATIONS OTHER WORK
(DD/MM) FROM MH MH Ft DISPOSED QTY PERFORMED&
RECOMMENDANTIONS
Jetted/Root Cut Debris level: None, light, medium,
heavy, roots, rocks
Jetted/Root Cut Debris level – None, light, medium,

heavy, roots, rocks

heavy, roots, rocks

heavy, roots, rocks

heavy, roots, rocks

heavy, roots, rocks

heavy, roots, rocks

heavy, roots, rocks

heavy, roots, rocks
TOTALS: Ft
OTHER COMMENTS:
Appendix F
VILLAGE OF WHITEFISH BAY APPENDIX F-1
Wet Weather SOP

1. PURPOSE
In the event that there is a wet weather event, there is a potential for basement backups
in the Village. To prevent wastewater from backing up into basements and creating an
immediate health hazard, the wastewater is diverted to a storm drain.
THIS PROCEDURE SHOULD ONLY BE DONE UNDER THE DIRECTION OF THE

VILLAGE MANAGER? DIRECTOR OF PUBLIC WORKS or designated
representative.
2. BACKGROUND
Under extreme wet weather events, the sanitary sewers are surcharged and have
caused basement backups. In order to prevent basement backups, the Village
bypasses flow to one of X gravity overflow points. . Several of these overflow points
have a piped connection with a valve from the sanitary sewer to the storm sewer. This
valve is normally closed unless manually opened. If the valve is opened, a sanitary
sewer overflow (SSO) occurs and must be reported.
In addition, there are X locations where the manhole can be submerged and basements
will backup. At these locations, the flow maybe pumped to a nearby storm sewer.
These are listed in Table F-1 (this is the same table in D-1 and Table 2-3 – do we want
to link these to ensure proper updates?) These locations can be found on a map
located in Appendix G – References.
See Overflow Response Plan Standard Operating Procedure ORP SOP for more
details.
3. PROCEDURE
USE THIS CHECKLIST AS A WAY TO KEEP A RECORD OF ACTIONS TAKEN.
1. If there is wet weather predicted (rain, snow meltdown), notify staff to advise on
emergency precautions.
2. If there is significant quantities of rain, check the manhole locations listed in
Table F-1 and as shown in the Critical Manhole Location Map.. The manholes
are listed by priority.
3. Have back-up portable pumps on trailer/truck
Wet Weather SOP_WFB_V1

June 2009 Page 1 of 4
4. Have blank copy of Sanitary Sewer By-Pass Summary Form (Located in

Appendix E)
5. Check pump by-pass locations first (Wilshire & Cramer, Lexington & Idlewild) If
flow is reaching top of pipe, install pump but don’t begin pumping. Begin
pumping when flow is over top of pipe. Critical point is 2” above. (above what?)
6. If the Whitefish Bay system is high and close to by-passing notify Shorewood
DPW at 847-. Do not wait until the Whitefish Bay system is by-passing or until
back-ups occur. If event occurs during non-business hours, notify Shorewood’s
Police Department non-emergency phone # @ 847-2610.
7. Check MIS manhole at Wilson & Courtland (west terrace area in park). If pipe
outfalls coming from east, south & north are under water sanitary back-ups in
Whitefish Bay system will occur.
• Notify Village Engineer. If Village Engineer is unavailable notify Village
Manager or call MMSD. See contact information in the ORP located in
Appendix D, Table D-1.
• If the Whitefish Bay system is underwater at the MIS – notify Village of
Shorewood immediately. If event occurs during after hours call the non-
emergency phone number @ 847-2610.
8. If MIS is surcharged - expect to by-pass at:
• Wilshire & Cramer,
• Lexington & Idlewild,
• Sheffield & Hampton,
• Diversey & Lancaster,
• Newhall & Chateau.
9. Only four locations operate with a portable pump.
10. All other locations are either valved and if open will flow into the storm sewer and
the others are gravity pipe from the sanitary sewer to the storm sewer.
11. At all locations that are by-passing, you need to monitor:
• The duration of the by-passing (flow) or pumping
• Depth of flow in by-pass pipe (inches)
• Size of by-pass pipe
• Pumping rate of pump (on the pump)
12. Notify Village Engineer immediately in the event of a by-pass event.
13. Estimated flow volume of the overflow must be calculated. At all locations that
are by-passing,
• Time and date gate valve opened. Time and date gate valve closed.

• Depth of flow in by-pass pipe (inches)

• Size of by-pass pipe
• Overflow –circle flow depth ¼ pipe ½ pipe ¾ pipe or full pipe
14. Notify Village DPW immediately if an overflow occurs.
15. See Overflow Response Plan (ORP) in Appendix D if for notification
requirements and details.
• All overflows must be reported. Notification must be received by DNR
within 24 hours of the start of the by-passing wastewater.
• See ORP Table D-2 for notification information.
• Notify North Shore Water immediately since the intake is located at Klode
Park.
• Notify Milwaukee Water Works within 12 hours of the bypass event.
•
4. SAFETY
Manholes are confined spaces. Confined Space entry is required.
5. REFERENCES
1. Appendix D - Overflow Response Plan (ORP) SOP

2. Appendix E – Forms
3. Appendix G – References
SOP DOCUMENT TRACKING

Document Name: Wet Weather SOP__WFB_V1
Author: Joan B. Hawley/Superior Engineering
Approved:
Issue Date: June 29th, 2009
Revised By: [Insert Name] Date: [Insert Date]

Table F-1
Village of Whitefish Bay Sanitary Sewer Overflow Points

Manhole
Circle Drive (near public walk
WB 16 to Marlborough) Overflow Site Valved Storm Sewer on Circle, to Lake Michigan (Silver Spring Outfall)
WB 20 Lake Drive @ Lake View Overflow Site Duck Bill Valve Storm Sewer on Lake Dr, to Lake Michigan (Silver Spring Outfall
WB 1 Montclair & Kent Overflow Site Gravity Pipe Storm sewer on Montclair, to Lake Michigan (outfall n/o Klode Park)
WB 6 Montclair & Bayridge Overflow Site Gravity Pipe Storm sewer on Montclair, to Lake Michigan (outfall n/o Klode Park)
WB 7 Montclair & Santa Monica Overflow Site Gravity Pipe Storm sewer on Montclair, to Lake Michigan (outfall n/o Klode Park)
WB 9 Montclair &Berkeley Overflow Site Gravity Pipe Storm sewer on Montclair, to Lake Michigan (outfall n/o Klode Park)
WB14 Montclair & Lake Dr Overflow Site Gravity Pipe Storm sewer on Montclair, to Lake Michigan (outfall n/o Klode Park)
WB 13 Monrovia & Lake Overflow Site Valved Storm sewer on Monrovia, to Lake Michigan (outfall n/o Klode Park)
WB 19 Diversey & Lancaster Overflow Site Gravity Pipe Storm Sewer on Lancaster, to Milwaukee River @Estabrook Park
WB 26 Sheffield & Hampton Overflow Site Valved Storm Sewer on Hampton, to Milwaukee River @Estabrook Park
WB 18 Newhall & Fairmount Overflow Site Gravity Pipe Storm Sewer on Newhall, to Lake Michigan (Buckley Park Outfall)
WB 23 Oakland & Lake Dr Overflow Site Gravity Pipe Storm Sewer on Lake Dr, to Lake Michigan (Buckley Park Outfall)
MH 157 Wilshire & Cumberland Overflow Site Gravity Pipe Storm Sewer on Wilshire, to Lake Michigan (Buckley Park Outfall)
MH 91 Newhall & Chateau Overflow Site Gravity Pipe Storm Sewer on Newhall, to Lake Michigan (Buckley Park Outfall)
MH 88 Lexington & Idlewild Monitored Site Portable Pump Storm Sewer on Idlewild to Lake Michigan (Silver Spring Outfall)
MH 162 Wilshire & Cramer Monitored Site Portable Pump Storm Sewer on Cramer, to Lake Michigan (Buckley Park Outfall)

Critical Manhole Locations
Appendix G
Critical Manhole Locations
Village of Fox Point
WB5002-2
42" MIS (Direct to MIS)
Legend
WB5008-3
Sanitary Manhole
State Highway 32
WB5008-1 Bypass Location and Bypass Identifier
WB5008-2 XXX
WB5008-1 LP
Load Point (LP) and Load Point Identifier
WB13 XXXX XX
8"
Pump
WB6 WB1 Flow Direction

WB7
E Montclaire Avenue
18" WB5008-2 LP WB5008-3 LP
MIS
15" 12" WB14
WB5007-4 LP Modeled Sanitary Main
8" 8"
12" Modeled Sanitary Force Main
WB9
Roads
WB5002-1 E Belle Avenue
Subsewershed Boundary
WB5002-1 LP
Sewershed Boundary
Sewer system from another

municipality included in this model
City of Glendale
42" MIS
Sewer system included
in another municipality model
8" WB5007-5
8" Flows included in another

WB5002-2 municipality model
WB20 WB5007-5
(Direct to MIS)
E Lake View Avenue Flows from another
8" municipality included in this model
WB5007-4
15" 12"
LA
K
E Silver Spring Drive
E
18"
MI
WB5007-2 LP
CH
12"
Sta
te
Hig
IG
hw
15"
ay
A
32
WB5007-3 LP E Birch Avenue
WB5007-2
N Santa Monica Boulevard
20"
WB5007-3
WBY 0 350 700 1,400 2,100 2,800
WB5001 WB5004-2 Feet
(Direct to MIS)
N Diversey Boulevard
WB5007-1 LP
WB5007-1
10" E Henry Clay Street

WB5004-2 LP
WB5004-3 LP
E Henry Clay Street
15"
22" 15" 15"
N
Pa
lis
ad
es
WB19
N Idlewild Avenue
Ro
WB5005-3
ad
WB5004-5 WB5004-3
(Direct to MIS)
WB5005-2
WB5004-5
E Fairmount Avenue 30" MIS 21"MIS

30" MIS
18" 15" WB5005-3 LP 12"
30" WB18 WB5004-1 LP
15"
WB23
WB5005-3
10"
E Chateau Place WB5005-2 LP
WB5009-2 WBX
(Direct to MIS)
WB5005-2
WB5005-4 WB5005-1
N Newhall Street
15" 12" WB5005-4 LP WB5005-1 LP E Hampton Avenue

N Berkeley Boulevard
10" WB26
10"
WB5004-1
WB5009-1 LP WBZ
N Oakland Avenue
42" MIS
WB5003-2 WB5004-4 LP
SH5006-3 LP WB5003-1 LP
8" N
La
21" WBW ke
Dr
WB5009-1 WB5004-4
ive
WB5003-3 WB5003-3 LP WB5003-1

30" MIS 18"
N
City of Milwaukee
W
ils
SH5006-1 LP WB5003-2 LP E Glendale Avenue

hir
e
Ro
From Shorewood (SH5006)

12" 8"
ad
15" SH5006-2 LP SH5

SH2 SH4
SH3
SH5006-3 To Shorewood (SH5006)
E Kensington Boulevard
SH5006-1 SH5006-2
Village of Shorewood

Modeled Sanitary Sewer System Schematic
7/14/2006
Modified by MMSD for Municipal CMOM
4/2007
This figure was compiled from a number of data sources for the
purpose of displaying the MOUSE model schematic and SECAP
project modeling results. Actual sizes, lengths, or other details of the
system components should be verified with the local municipality
and /or MMSD before using in any subsequent analyses, design, or other purposes.
Table G-1
Village of Whitefish Bay Performance Measures
DESCRIPTION 2009 GOALS 2010 GOALS
SEWERS
Total Sewer Length in Feet 204,336
Sewers cleaned (Feet/year – ft/yr) 20% 40,867 ft/yr 20% 40,867 ft/yr
Sewers inspected - 20% 40,867 ft/yr 20% 40,867 ft/yr
MANHOLES (MH)
Number of Manholes in System 905
Manholes inspected 20% 181 MH/yr 20% 0 MH/yr
REHABILITATION/REPLACEMENT DESCRIPTION
Numbers of manholes repaired 10 MH
Number of manholes lined/sealed 109 lf
Number of manholes replaced 383 vf
Sewer Lining 8" 3,403 feet
Sewer Lining 10" 368 feet
Sewer Lining 12" feet
Sewer Lining 15" 190 feet
Sewer Replaced 8",10",12 4835 feet
Sewer Replaced 30" 451 feet 9,000 feet
Sewer Spot Replacement 8-18" 400 feet
Lateral Replaced 6" 5,634 lf
Laterals Spot Relay 35 each 300 each
MAINTENANCE ACTIVITIES
Root Removal - (see Appendix G - root cutting schedule) See Map feet
Smoke Testing TBD feet
Dye Water Flooding TBD feet
Flow Monitoring percent of the collection system TBD %
TRAINING
Compliance with WI Administrative Code Comm 32
STIPULATION COMPLIANCE
Compliance with Tributaries Stipulation (Appendix B - see Note 1)
REPORTING
Report per Table 8-1 Requirements See Table 8-1
Number of basement backups from Village sewers 0 each
Number of basement backups from Private property laterals 0 each
Total number of backups 0 each
Number of Sanitary Sewer Overflows 0 each
Note 1:
The Village of Whitefish Bay “agree[s] that they will encourage and support MMSD’s continuing development, implementation, and
management of flow monitoring and rain gauge systems and peak flow performance standards." The Village "retains all legal rights
to object to and appeal any rules and standards implementing such MMSD activities. "
Updated February 25th, 2010

2010 Whitefish Bay CMOM Plan

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2010 Whitefish Bay CMOM Plan

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VILLAGE OF WHITEFISH BAY

CAPACITY, MANAGEMENT, OPERATIONS, MAINTENANCE

SECTION 1 – Overview ..............................................................................................................1

SECTION 2 – Management Plan................................................................................................4

SECTION 3 – Operation And Maintenance Plans…………………………………………………14

SECTION 4 – Capacity Plan …………………………………………………………………………18

SECTION 5 - Overflow Response Plan …………………………………………………………….20

SECTION 6 - Condition Assessment Program …………………………………………………….22

SECTION 7 - Communication Plan …………………………………………………………………23

SECTION 8 – Audit Plan……………………………………………………………………………...24

APPENDIX A – Reference Stipulation - Satellite Municipalities

APPENDIX B – Reference Stipulation – Milwaukee Metropolitan Sewerage District

APPENDIX C – Reference CMOM Strategic Plan January 2008

APPENDIX D - Overflow Response Plan

APPENDIX F – Standard Operating Procedures (SOP)

1. Wet Weather SOP

SOP APPENDIX G – References

1.1 Background and Information

A Capacity, Management, Operations and Management (CMOM) Plan is required to comply

1.2 CMOM Program Objectives

1. Ensures that communities have adequate wastewater collection capacity.

In addition to these objectives, an effective CMOM program also:

1. Protects human health including drinking water, swimming, blood-born pathogens,

1.3 CMOM Program Components

The CMOM Plan includes the following components:

• Section 2 Management Plan

For the purpose of this document the following definitions pertain:

1. CMOM Capacity, Management, Operations and Maintenance. A program to efficiently

reaching treatment facilities thereby escaping wastewater treatment. It is also

1.5 Stipulation Summary

Table 1-1 Stipulation Summary – Village of Whitefish Bay

2.1. Background and Information

2.2. MISSION STATEMENT

To protect the Health, Safety and Overall Environment of our

1. Comply with WPDES permit

2. Minimize the occurrence of problematic overflows

3. Improve or maintain system reliability

4. Maintain assets cost-effectively through a rehabilitation and replacement program

5. Provide first-class customer service

6. Reduce the potential threat to human health from sewer overflows

7. Protect collection system worker health and safety

8. Provide adequate capacity to convey peak flows

9. Manage Infiltration and Inflow

10. Operate a continuous CMOM Program

2.4. Organization Structure

Table 2-1 Village Staff Responsibilities

2.5. Management of Assets

Managing assets cost-effectively is a key CMOM program goal.

• North Lake Drive Sewer

2.6. Customer Service

See Section 7 Communication Plan for other details related to communications.

2.7. Legal Authority

• Sanitary Code – Chapter 10

• Plumbing Code – Chapter 13

• Maintenance of Property – Chapter 18

2.7.1. Sewer Use/Sanitary and Plumbing Codes

2.7.2.3. Grease traps or separators must be properly maintained and cleaned on a

2.7.3. The Village also complies with the following:

2.8. Fiscal programs

• O&M Programs - see Section 3.

• Condition Assessment Programs - see Section 6.

• Recommendations to reduce I/I.

2.9. Data Management