eRPortal whitepaper EPA pressure and fiscal responsibility

Computerized asset management of wastewater treatment systems is not yet required by the United States Environmental Protection Agency (EPA), but the EPA is pushing hard for adoption of best practices such as capacity management, operations and management (CMOM), and the penalties levied by the EPA for system leakages can be severe. Download this paper to learn more.

e R P o r ta l Software Gro up EPA Pressure & Fiscal Responsibility Driving the Need for Computerized Asset Management Waste-Water Treatment Facility Managers Require The Ability To Produce Reports That Prove Assets Are Managed Properly and To Justify Budget Expenses Computerized asset management of waste-water treatment systems is not yet required by the EPA, but it may very well become a requirement within the near future. But even if computerized asset management (often referred to as automated asset management) does not become mandatory, the EPA is pushing hard for adoption of best practices such as CMOM (Capacity Management, Operations and Management), and the penalties levied by the EPA for system leakages can be severe. It makes sense for municipalities to give strong consideration now to the CMOM guidelines issued by the EPA on best-practices for managing the physical assets of waste-water systems. If a municipality pollutes the environment without any automated asset management system, the EPA may jump all over them. The CMOM guidelines help avoid the problems of waste-water systems that might have been put in the ground as many as 75 years ago by showing how to manage the infrastructure. No EPA audits are planned for now, but with the ever-increasing political pressure to safeguard the environment, the chance of the EPA conducting audits will always lurk over the heads of waste-water facility managers. The EPA may eventually reach the point where it will demand to review asset management reports on a regular basis to see if municipalities can prove they properly follow CMOM regulations. With or without asset management becoming an EPA requirement, if a city or town has a leakage problem, the EPA can still issue severe penalties. So it's best to apply best practices such as CMOM in advance just in case. Preventative maintenance and inspections that can be demonstrated via an automated asset management solution may help a municipality avoid large penalties down the road. Current Approaches to Waste-Water Asset Management Most plant superintendants and facility directors are well-aware of the EPA pressures. They may already be determining whether or not to have their staffs adopt a new solution in addition to requesting their city or town to allocate capital expenses to address the computerized asset management challenge. But many municipalities continue to rely on a manual asset-management approach, which may include hand- written notes kept on file, Excel spreadsheets, or a combination of the two approaches. They often keep replacement components in stock and run various equipment components until they fail. When this occurs to a waste-water system, maintenance may not be a major issue—as long as nothing leaks into the environment. Many municipalities take the approach of simply replacing components when they break. When components to a waste-water system break, there also are almost no obstacles in terms of budgeting. Cities and towns usually will readily provide the funding so that waste water will continue to flow and be treated properly. Managers and directors may also take the approach of maintaining, refurbishing or replacing equipment on a calendar basis but without considering the level of utilization. But the EPA is now saying these approaches may not be sufficient. Waste-water leaks may not immediately impact citizens, but they could have a negative long-term impact on the environment. The EPA thus wants to see municipalities properly manage and employ preventative maintenance for filters and pumps at plants as well as for underground assets based on utilization rates rather than maintaining them on a calendar basis. Even if the specter of the EPA enforcing asset management did not exist, many cities and towns are taking a serious look at automated asset management because they realize the need to make annual budgets leaner in these tough economic times. Water- treatment facility managers have reacted by becoming savvier about asset productivity and efficiencies. Some municipalities have already deployed automated asset management systems, but many continue to rely on manual systems. Waste-water leaks may not immediately impact citizens, but they could have a negative long-term impact on the environment. The EPA thus wants to see municipalities properly manage and employ preventative maintenance for filters and pumps at plants as well as for underground assets based on utilization rates rather than maintaining them on a calendar basis. The Challenges of Manual Asset Management When using a manual system such as hand-written notes or computer spreadsheets, it is possible to properly manage assets as long as all system users are diligent about taking notes and updating spreadsheets correctly. But where the challenge emerges is when it comes time to create reports to produce an accurate accounting of what's been done to manage the assets. If working with hand-written notes or spreadsheets, it can be next to impossible to demonstrate to the EPA what has been done to properly manage assets. It may also be very difficult to justify budgetary expenses to municipal boards. To even come close to solving either challenge, it would require neatness, clarity, safe storage, logical organization, and complete notes of system log-ins. EPA Pressure and Fiscal Responsibility Driving The Need For Computerized Asset Management A water facility manager may indeed be doing all the right things when it comes to asset management. But if the EPA or a municipal board wants to review the past year or multiple years to confirm that asset management is being executed properly, or if they want to see what was done on a particular section of the system, it could be difficult for the facility manager to accurately present their case. Proper summarizing may be impossible. Even if all the necessary information exists in a spreadsheet, the facility manager may not have recorded all the information in all the right places to close all the loops on connections between assets and the procedures that that need to be performed on the assets. Manual systems live and die on the ability of users to input all the necessary data. There are no warning messages when information is left blank, and management cannot easily review hand-written notes and spreadsheets for missing data. While it's true Excel spreadsheets can be manipulated to produce reports showing current activity, the software is not a sufficient repository for data. The ability to produce historical data is lacking. If and when the time comes to face an audit by the EPA, facility managers may actually be doing all the right things. But if they can't prove it, their municipality will most likely receive severe penalties. Lack of automation also makes it difficult and can create headaches on deciding how to budget time, money and other resources towards asset management. Managers need to be able look at the record of past work and perform analysis to make better forecasting decisions on what to do and what to follow-up on. They also need to be able to do intelligent planning on expenditures so they can plan what can be refurbished vs. what needs to be replaced vs. basic maintenance and they need to be able prove why when they ask their municipality for more money. Manual systems and Excel reports may prove difficult to give an accurate picture of what happened in the past so that convincing a municipality to allocate the necessary budget may be impossible. The Barriers To Automated Asset Management Many waste-water facility managers have realized for some time that they need to deploy an automated asset management solution, but they may be hampered by budget constraints for the capital expenditure. Even though funds to buy replacement pumps and hardware as well funds as to hire electricians and plumbers to fix equipment tend to be readily available, it's difficult to get municipal boards to allocate funds for new capital expenditures, such as software systems, especially if there's any doubt about whether asset management expenditures will help. There could also be fear that a municipality will overspend. EPA Pressure and Fiscal Responsibility Driving The Need For Computerized Asset Management Even if a municipality secures the necessary budget allocation, they may fear choosing the wrong product or vendor. Facility managers need to partner with a solution provider that already knows their operations or is willing to spend the time to understand their particular needs. Facility managers might also be unsure if an asset-management solution will be easy for users to adopt. This is especially true for users accustomed to older systems that might have been in place for many years. A process-change will become necessary, and that is not an easy undertaking for any organization with staff that have been on board for a long time. And if the process-change does not work, there could be pressure and finger pointing for not selecting a working solution. The staff could actually rebel and refuse to use the solution. Taking Steps Towards Automation The first step is to choose a partner that can advise you on which automated asset management solution to deploy. Ideally you should partner with a firm that can refer you to software provider that can design and deploy the solution components for you. Many reputable national and regional engineer firms are familiar with the challenge and are well-entrenched in the waste-water industry, having taken municipalities through the solution vendor selection process often. It's important to make sure the software firm you work with deploys a solution that interfaces to your SCADA (Supervisory Control and Data Acquisition) system. Your SCADA vendor is actually another resource to consider for helping you find an automated asset management software firm. SCADA vendors can especially help direct you to firms that can integrate their asset management solution with your SCADA system. This further enhances the ability to trigger maintenance activity based on actual equipment condition and utilization levels. The integration helps pinpoint when to maintain, refurbish or replace an asset. Although it may add to the overall cost of your solution, it's generally best to work with an engineering firm or your SCADA vendor to help you evaluate different solutions. They can help you take into account how each asset management solution fits into your overall operations. EPA Pressure and Fiscal Responsibility Driving The Need For Computerized Asset Management Asset Management Solution Question Checklist When working with an engineering partner to help you choose the right automated asset management solution, be sure to ask them about the key attributes of the solution they recommend. Here is a set of questions to guide you and your solution partner to the solution that best fits your facility's needs:  Is there documentation to help justify the cost of the solution in advance to the municipality so that budget approval will be possible? Is the ROI sufficient and can it be demonstrated?  How easy is it to build and publish reports for EPA audits and for proving asset value to the municipality?  What is the overall cost of the various components? o Software o Hardware o Deployment services o Training services o Ongoing support services o Amount of downtime for operations during deployment  How easy is the software to use and is it flexible?  Will users pick-up the software easily and adapt to using it compared to what they are used to?  Can users make the culture change from your old system to your new system?  Will the software sync with current work processes?  Can the solution be shaped to each user's daily tasks and responsibilities so that when each user logs-in, they see only the functions that apply to their job role?  Can end-users take a test run and provide their feedback?  Can the system integrate with the various systems already in place? o SCADA o GIS o Financial/Accounting systems If the automated asset management solution can be integrated with your SCADA, GIS or financial system, this will help with ROI justification since it streamlines overall operations and increases ROI on the other solutions. This also shows how the waste- water treatment facility contributes to overall fiscal responsibility. EPA Pressure and Fiscal Responsibility Driving The Need For Computerized Asset Management Features To Look For In An Automated Asset Management Solution A good asset management solution vastly increases the effectiveness of the facility operator and maintenance workforce. The implemented solution should be an easy-to- use, maintenance-management system that tracks and automates all maintenance activities. The solution should also effectively manage both planned and unplanned work- order logistics while being flexible towards how the plant operates as well as how the department tracks time, materials and workloads. An effective solution also allows facilities to start small in terms of the number of users as well as data entry and then grows as needs change. Be sure to look for a solution that includes all of these capabilities: o Features that provide enough flexibility to control when work orders should be triggered—by any combination of factors including date range, machine run-time, hours-of-use, and start-stop. o The ability to manage all the components of work orders once they are triggered, including procedures, parts, assigned staff, skill and labor codes, time, materials, schedules, dates, and responsiveness. o Parts-and-materials management features that allow for the tracking of which parts should be on-hand, at what location, at what time, and for what machine or asset. o The ability to manage preferred vendors, blanket purchase orders, and procurement contracts as well as inventory and item properties. This includes multiple cost methodologies, serialization/lot numbers, weight, description, type, class, and dimensions. o The ability to utilizes existing barcode IDs or create new ones on-demand or at the time of purchase-order receipts. This streamlines maintenance procedures by identifying, allocating, and tracking replacement parts and the equipment required for reoccurring tasks. Once a waste-water treatment facility manager or director makes the commitment and computerizes the asset management process, they will improve their ability to prevent system faults, breakdowns and equipment malfunctions. This will improve overall operations efficiency and will help prevent leakages that could lead to EPA penalties. EPA Pressure and Fiscal Responsibility Driving The Need For Computerized Asset Management The Ultimate Benefits of Automated Asset Management Once a waste-water treatment facility manager or director makes the commitment and computerizes the asset management process, they will improve their ability to prevent system faults, breakdowns and equipment malfunctions. This will improve overall operations efficiency and will help prevent leakages that could lead to EPA penalties. The automated asset management system will also give the municipality the ability to take-on EPA audits should one be required. If this occurs, the waste-water facility manager will be able to produce reports that prove the due diligence applied to asset management and just might help the municipality avoid or significantly reduce any fines the EPA might issue. Facility managers and directors will also be able justify why their budget can't be reduced or why their budget needs to be increased. And if facility managers are simply forced to reduce the budget, they can plan better on how to cut costs. Whether or not the EPA enforces CMOM, it's clearly a good idea to automate asset management now because replacing and refurbishing assets may not always be options in today's economic climate. Water supply and water treatment is not just about making the citizens happy. Facility managers also need to spend wisely and prove intelligently why more capital is required when the need arises. Without automated asset management, these tasks are next to impossible. For more information on computerized asset management solutions for waste-water systems, contact Edward Garibian, President of eRPortal Software Group at 866-326- 2757 or egaribian@erportalsoftware.com or visit www.erportalsoftware.com. EPA Pressure and Fiscal Responsibility Driving The Need For Computerized Asset Management Who Will Be Affected by CMOM? (as posted on www.epa.gov) Every collection system owner (whether they have wastewater treatment facilities or not) will be required to obtain an NPDES permit. The owner must provide adequate capacity to convey base and peak flows, develop a plan to eliminate sanitary sewer overflows, and develop a preventative maintenance management program for the collection system. A formal CMOM compliance audit will assure participation, which may be self- administered by the utility. What does CMOM mean to Collection System Owners? The resulting health and environmental risks from pooly-performing collection systems give need to increased regulatory oversight of the management, operation and maintenance of these systems. CMOM is intended to provide a more efficient approach to controlling SSO’s through an increased focus on system planning. The proposed rule would establish standard permit conditions for inclusion in existing NPDES permits and a means of regulating satellite systems:  Capacity, Management, operation and maintenance requirements  A prohibition on discharges  Reporting, public notice and record keeping for discharges. Collection system owners should anticipate investment costs to manage and implement the CMOM program, both in terms of additional resources and capital improvements. It is believed that this increased investment will lower O&M costs, reduce the occurrence of sewer overflows and provide a health benefit to the public community. What happens in the event of an Overflow? If an overflow occurs, the owner will be required to:  Implement a documented overflow response plan that includes public and regulatory notification  Notify the public that could be affected  Make available a summary of their CMOM program, related audit activities, and results to interested parties. What steps should Collection System Owners take? CMOM programs are developed, managed, maintained, and administered by collection system owners. The first step is to perform an internal CMOM audit to identify the strengths and deficiencies of the organization. Depending on these results, owners may need to modify their O&M procedures, or implement condition assessment and hydraulic analysis programs that restore or improve capacity. Where can Owners find more information?  A site was established by the WEF at www.CMOM.net. It is intended to be a clearing house for information related to the CMOM initiative.  The EPA provides a checklist for assessing sewer system programs.  A copy of the SSO proposed rule may be found on the EPA’s web site at www.epa.gov/npdes.  The draft regulation is 40 CFR 122.42(f) and may be found on the EPA’s web site at the link above. What is the estimated cost to implement CMOM? What is the source for the funding? The EPA estimates that the costs to address SSOs caused by wet weather conditions and maintenance issues would result in an average household expenditure of between $75 and $160 per year. There are waivers available for systems that serve less than 2.5 mgd. The CWA established a State Revolving to provide low interest loans for major, and some minor, replacements of sanitary sewer system components. EPA Pressure and Fiscal Responsibility Driving The Need For Computerized Asset Management