Collection System Action Plans

Rule 62-600.705(2), F.A.C., became effective on June 28, 2023, and requires all domestic wastewater facility permittees to develop a pipe assessment, repair, and replacement action plan for the facility's collection system, i.e., a collection system action plan. A summary of the plan must be submitted to DEP with the next facility permit application for any new permit, permit renewal, or substantial permit revision. Additionally, after a facility permittee has developed and submitted a collection system action plan to DEP, an annual report on the implementation of the plan must be submitted each year by June 30.

The goal of a collection system action plan is to prevent sanitary sewer overflows (SSO) and leakages that may endanger public health and the environment. The plan is a proactive approach to assess the condition of the collection system to identify needed maintenance, repairs, and rehabilitation of the system.  

Development of a Collection System Action Plan

The following items should be considered, at a minimum, when developing a collection system action plan:

• The plan must cover at least a 5-year planning horizon for all collection/transmission systems under the utility’s control and the plan’s detail must reflect the complexity of the system.
• The plan must set goals for evaluating percentages of the collection system each year with a minimum of 25 percent of the collection system evaluated over the five-year planning horizon. Evaluations and assessments may be made using one or more investigative techniques such as camera inspections, smoke testing, data analytics, flow isolation, focused electrode leak location, direct observation, and sonar imaging, water chemistry, and solids analysis, or flow monitoring.
• The plan must be based on infiltration and inflow (I&I) studies, leakage surveys, and any follow-up detailed sanitary sewer evaluation surveys.
• The plan must include a map and inventory of the collection system. Facilities with a permitted capacity over 1 million gallons per day must have a computerized GIS map and electronic inventory. Inventory items include:
  
  • Detailed information on each section of pipe, manholes, and pump stations including inspection and maintenance information.
  • Climatic, geologic, topographic, and hydrological information including seasonal high water table information and rainfall data.
  • Information on system flows, SSOs, bypasses, odor complaints, corrosion data, and past I&I analyses, as well as population and industries served.
• The plan must include an adaptive maintenance and repair plan including protocols for routine maintenance, cleaning activities, and emergency repairs.
• Contact information and recordkeeping procedures.
• The plan shall describe measure, if any, taken for the following:
  
  • To limit fats, oils, grease, wet wipes, sand, and grit into the collection system, and a root control program.
  • Any local sewer ordinances or programs to minimize I&I from private sanitary sewer laterals/individual service connections.
  • Resiliency for sea-level rise and flood mitigation and stormwater control actions.
• After December 21, 2025, identify all satellite collection systems connected to the facility collection system.

Annual Report Requirements

The facility must submit an annual report summarizing plan by June 30 of the year following the fiscal year covered by the report. The report must include, at a minimum:

• A summary of assessments conducted, results of the assessments, and the percentage of the collection system assessed.
• Significant repairs, replacements, maintenance activities, expansions and upgrades conducted during the year and any planned for the upcoming year.
• After December 21, 2025, identification of new satellite collection systems.
• Information on annual expenditures for I&I studies, implementing the collection system action plan, repairs, replacements, and measures related to limiting fats, oil, grease, roots, wet wipes, sand, and grit in the collection system.
• Details of facility revenues and expenditures related to the collection system.
• Any other activities and information deemed relevant by the permittee.

Reference Material

• EPA CMOM Guidance for Collection Systems
• Core Attributes of Effectively Managed Wastewater Collection Systems
• Sewer System Infrastructure Analysis and Rehabilitation – Handbook. EPA/625/6-91/030
• Exfiltration in Sewer Systems – Project Summary. EPA/600/SR-01/034
• Asset Management Programs for Stormwater and Wastewater Systems: Overcoming Barriers to Development and Implementation