As you know from earlier E-bulletin posts, EPA may be making changes to the way it regulates municipal sanitary sewer collection systems and sanitary sewer overflows. CWEA, along with its partner organizations – BACWA, CASA, CVCWA, SCAP, and Tri-TAC – has submitted a comment letter to assist EPA in protecting our water resources while keeping our workforce strong.
Some key points include:
- We have a unique perspective on the advisability and effectiveness of a new federal regulatory program for SSOs, because for the past four years, our locally-owned systems have been operating under a comprehensive statewide program that requires permitting, planning and online reporting of SSOs. We have a strong interest in
ensuring that any new federal program is compatible with the California requirements and that the significant investments already made in collection system infrastructure, planning and reporting are not undermined. Read more
WEF has submitted comments to to help EPA determine whether and how to modify the National Pollutant Discharge Elimination System (NPDES) regulations as they apply to municipal sanitary sewer collection systems and sanitary sewer overflows (SSOs).
The Water Environment Federation (WEF) fully endorses EPA’s decision to collect information and views in support of developing a comprehensive program addressing sanitary sewer overflows (SSOs) and peak flows. These critical environmental management issues must be effectively addressed in order to improve both the quality of our nation’s waters and the health and safety of local communities. WEF stands ready, as always, to technically support EPA in these efforts.
Read the full comment letter. WEF also contributed a presentation on benchmarking sanitary sewer maintenance programs.
Comments are due August 2. Visit EPA’s site for more information.
Does your organization serve a population of 2,500 or less? If so, the Design and Performance Provisions, System Evaluation and Capacity Assurance Plan, Monitoring and Program Modifications, Program Audits and Communication Program elements and the final SSMP will be due by August 2, 2010. If you are a publicly owned collection system with more than one mile of pipeline you must have developed a SSMP after August 2, 2010 deadline. In order to be compliant, this August 2nd deadline requires you to have a developed and implemented your SSMP regardless of the population you serve
The next phase of the SSMP for collection systems under the statewide program will be state conducted audits. Audits will occur at least every two years. Your organization must prepare and retain a SSMP report on file. All audits will concentrate on how adequate the SSMP and the enrollee’s compliance with the SSMP requirements including identification of any deficiencies in the SSMP and steps taken to correct them. The due date of an audit is every two years from the date your agency obtained approval from their governing body. May 2011 will be the first audit date for an agency serving a population of 100,000 or more. August 2011 will be the first due date for agencies serving populations between 10,000 and 99,999.
CWEA staff joined 1,000 participants across the country at EPA’s July 14 public listening session webcast on its efforts to initiate rulemaking to address sanitary sewer overflows and to resolve longstanding issues concerning peak flows. Visit www.epa.gov/npdes/sso to see EPA’s presentation, which provided an overview of the rulemaking being considered. An audio transcript will be posted soon.
Written comments are due by August 2, 2010.
EPA is seeking input on the following questions:
- Should EPA clarify its standard permit conditions for SSO reporting, recordkeeping, and public notification?
- Should EPA develop a standard permit condition with requirements for capacity, management, and operations & maintenance programs based on asset management principles?
- Should EPA require permit coverage for municipal satellite collection systems?
- What is the appropriate role of NPDES permits in addressing unauthorized SSOs that are caused by exceptional circumstances?
- What is the appropriate role of NPDES permits in addressing unauthorized SSOs that are caused by exceptional circumstances?
- How should EPA address peak flow diversions at POTW treatment plants?
- How should municipalities balance all of the needs to meet water quality requirements?
EPA announced in the June 1 Federal Register that it plans to hold several listening sessions to obtain public input on a proposed strategy to reduce SSOs and basement backups. The EPA seeks to modify the National Pollutant Discharge Elimination System (NPDES) regulations as they apply to municipal sanitary sewer collection systems and SSOs by establishing standard permit conditions for POTW permits, and clarifying the regulatory framework for applying NPDES permit conditions to municipal satellite collection systems. Read more
The U.S. Environmental Protection Agency (EPA) is initiating a rulemaking to better protect the environment and public health from the harmful effects of sanitary sewer overflows (SSOs) and basement backups. In many cities, SSOs and basement backups occur because of blockages, broken pipes and excessive water flowing into the pipes. SSOs present environmental and health problems because they discharge untreated wastewater that contains bacteria, viruses, suspended solids, toxics, trash and other pollutants into waterways. These overflows may also contribute to beach closures, shellfish bed closures, contamination of drinking water supplies and other environmental and health concerns.
EPA Deputy Administrator Robert Perciasepe announced during the National Association of Clean Water Agencies’ National Environmental Policy Forum on April 20 that EPA expects to propose by late spring or early summer a policy that would address overflows from sanitary sewer systems. The new policy will look at previous proposals on the topic, and consider what has been learned since that time, said Perciasepe. In the absence of a policy for controlling sanitary sewer overflows, EPA may make an announcement soon on moving forward with some sort of policy and has indicated a preference to address the issue of blending under the broader sanitary sewer overflow (SSO) policy. NACWA has threatened to petition EPA to establish a consistent policy on how sanitary sewer overflows (SSOs) and collection systems are treated due to concerns that EPA will view every overflow as illegal and in violation of the Clean Water Act. Perciasepe also stated during the forum that EPA is evaluating how to integrate wet weather issues, including stormwater, and is looking at stormwater “more holistically.”
As part of their “Toxic Waters” series the NY Times on Monday looked at New York City’s wastewater collection and treatment system and found it’s frequently overwhelmed when it rains – leading to combined sewer overflows (CSO).
The article, titled Sewers Fill, Waste Poisons Waterways, sums up the dire situation: “Despite (billions in) upgrades, many sewer systems are still frequently overwhelmed, according to a New York Times analysis of environmental data. As a result, sewage is spilling into waterways.”
The article looks closely at the Owls Head WPCP in Brooklyn and the obstacles operators face in treating storm flows…
“The public has no clue how important these sewage plants are,” said Bob Connaughton, the Plant Engineer. “Waterborne disease was the scourge of mankind for centuries. These plants stopped that. We’re doing everything we can to clean as much sewage as possible, but sometimes, that isn’t enough.”
The NY Times series on water is one of many this year that captured the public’s attention. There’s also the PBS-Frontline special Poisoned Waters about stormwater pollution and the AP’s on-going series about prescription drugs flushed down the drain (a huge no-no of course!) and their impact on ecosystems. The Atlantic magazine hosted a water conference last month in DC about dwindling supplies of clean water. And so on…
Perhaps the years of public outreach by CWEA, WEF, WIN, NACWA and WWEMA (Water and Wastewater Equipment Manufacturers Association) are finally paying off with more public coverage of America’s crumbling water/wastewater infrastructure.
With the State gearing up for enforcement, you don’t want to be caught out of compliance. CWEA is offering two SSO-WDR compliance workshops throughout California. Each Workshop will give you up to 7 CWEA Contact Hours in Collection Systems and includes morning coffee and lunch.
Register Now: Full SSO-WDR Workshop Brochure
Sessions details after the jump…
Tri-TAC and several additional clean water Associations jointly called upon the SWRCB for equitable and reasonable standards in their SSO abatement program…
From the letter…
The Associations believe that the program is at a point where the State Water Board could most positively focus its resources on achieving compliance with the existing program, which has not yet been completely implemented. The slide show presented by State Water Board staff at the September workshops indicated that nearly forty percent of agencies are not reporting on a regular basis. Fifteen percent of agencies have not even completed the CIWQS questionnaire.
Only half of the agencies have certified completion of their SSMPs. The lack of reporting by the non-compliant agencies is unfair to the agencies that are reporting, and the map of spills shown on the Water Board’s website is misleading to any viewer of the website because of the agencies that are not yet included in the program or are not reporting appropriately.
(hat tip: Elizabeth Allen!)
