Framework for CSO Control Planning EPA CSO LTCP Review Workshop December 8-9, 2004 Philadelphia, PA Framework for CSO Control Planning Michael Sullivan Limno-Tech, Inc. Framework for CSO Control Planning

EPA CSO LTCP Review Workshop December 8-9, 2004 Philadelphia, PA Material to be Covered CSO Control Policy Nine Minimum Controls (NMC) Long-term Control Plans (LTCPs) Small System Considerations Framework for CSO Control Planning Framework for CSO Control Planning

Gambles Hill CSO Outfall Prior to CSO Control (1996) Framework for CSO Control Planning

Framework for CSO Control Planning CSO Outfall Framework for CSO Control Planning

Objective of CSO Control EPA CSO LTCP Review Workshop December 8-9, 2004 Philadelphia, PA Objective of CSO Control Bring CSO discharges into compliance with Clean Water Act requirements and applicable State WQ standards Eliminate CSO discharges where possible Framework for CSO Control Planning Framework for CSO Control Planning

Four Key Principles of CSO Control Policy EPA CSO LTCP Review Workshop December 8-9, 2004 Philadelphia, PA Four Key Principles of CSO Control Policy Provide clear levels of control Provide sufficient flexibility Allow a phased approach Review and revise, as appropriate, WQS and WQS implementation procedures when developing LTCPs Framework for CSO Control Planning Framework for CSO Control Planning

Roles of Permitting Authorities are Key EPA CSO LTCP Review Workshop December 8-9, 2004 Philadelphia, PA Roles of Permitting Authorities are Key Facilitate and coordinate the CSO control program Ensure coordination among WQS authorities, enforcement authorities, public and permittee Coordinate CSO control efforts with water pollution control needs on a watershed management basis Provide leadership Consider the financial capability of permittees when reviewing CSO control plans Framework for CSO Control Planning Framework for CSO Control Planning

Overview of CSO Controls EPA CSO LTCP Review Workshop December 8-9, 2004 Philadelphia, PA Overview of CSO Controls NMC – Technology-based controls, require documentation and annual reporting LTCP – Water quality-based controls Presumption approach Demonstration approach Framework for CSO Control Planning Framework for CSO Control Planning

Small System Considerations The CSO Control Policy recognizes that the scope of the long-term control plan, including the characterization, monitoring and modeling, and evaluation of control Alternatives, may be difficult for small communities. Framework for CSO Control Planning

What are the Expectations for Small Communities? Implement the nine minimum controls Develop an abbreviated Long-Term Control Plan to cover: Prioritization of the control of CSOs in sensitive areas Implementation of a public participation process that actively involves the affected public in the selection of CSO controls Evaluation of controls and development of a proposed plan for CSO control. Framework for CSO Control Planning

What are the Nine Minimum Controls? The NMCs are minimum technology-based controls that can be used to address CSO problems -- without extensive engineering studies or significant costs -- prior to implementation of long-term control measures. Framework for CSO Control Planning

Framework for CSO Control Planning NMC 1: Proper operations and regular maintenance programs for the CSS and CSO outfalls Framework for CSO Control Planning

NMC 2: Maximum use of the CSS for storage EPA CSO LTCP Review Workshop December 8-9, 2004 Philadelphia, PA NMC 2: Maximum use of the CSS for storage Framework for CSO Control Planning Framework for CSO Control Planning

Framework for CSO Control Planning NMC 3: Review and modification of pretreatment requirements. Besides SIUs, small communities may want to focus on other users or groups of users such as: Hospitals Photo processors Dry cleaners Laundries Auto body shops Dentists Garages Gas Stations Restaurants Landfill leachate Printers Car Washes Framework for CSO Control Planning

NMC 4: Maximization of flow to the POTW for treatment Framework for CSO Control Planning

NMC 5: Elimination of CSOs during dry weather Framework for CSO Control Planning

NMC 6: Control of solid and floatable materials in CSOs Framework for CSO Control Planning

NMC 7: Pollution prevention programs Framework for CSO Control Planning

NMC 8: Public notification Framework for CSO Control Planning

Framework for CSO Control Planning NMC 9: Monitoring to effectively characterize CSO impacts and the efficacy of CSO controls Framework for CSO Control Planning

What is a Long-Term Control Plan? The LTCP is a comprehensive plan that recognizes the site-specific nature of CSOs and their impacts on receiving waters. The final LTCP should include water quality-based control measures that are technically feasible, affordable, and consistent with the CSO Control Policy Framework for CSO Control Planning

Nine Elements of an LTCP for Large CSO Communities EPA CSO LTCP Review Workshop December 8-9, 2004 Philadelphia, PA Nine Elements of an LTCP for Large CSO Communities Characterization, monitoring and modeling Public participation Consideration of sensitive areas Evaluation of CSO control alternatives Cost/performance considerations Operational plan Maximization of treatment at the POTW Implementation schedule Post-construction compliance monitoring Getting back to the nine elements of a LTCP, the Eval of CSO controls actually includes four of the elements. Framework for CSO Control Planning Framework for CSO Control Planning

Elements of an LTCP for Small CSO Communities Required in CSO Control Policy: Consideration of sensitive areas Public participation Evaluation of CSO control alternatives Useful or likely to be required: Characterization (not necessarily monitoring and modeling Maximization of treatment at the POTW Post-construction compliance monitoring Framework for CSO Control Planning

EPA CSO LTCP Review Workshop December 8-9, 2004 Philadelphia, PA LTCP Approaches Demonstration and Presumption Approaches Two alternative methods for developing a water quality-based control program in the LTCP Provide CSO communities with targets for CSO control that are presumed to meet the water quality-based requirements of the CWA Framework for CSO Control Planning Framework for CSO Control Planning

EPA CSO LTCP Review Workshop December 8-9, 2004 Philadelphia, PA LTCP Approaches Presumption approach (performance based) Demonstration approach (more of a watershed approach and based on data) Combination of Presumption and Demonstration approaches (used by some communities) There are two basic approaches to CSO control – the presumption approach and the demonstration approach. The presumption approach is performance based - in that it requires control up to a certain performance level . The demonstration approach is more of a watershed approach in that it requires a level of control adequate to meet WQ-based requirements of the CWA. Demonstration originally considered to be a lower level of control WQS must be met under both approaches, and there is some confusion in distinguishing between them. Some communities use Presumption for one receiving water and demo for another. Framework for CSO Control Planning Framework for CSO Control Planning

EPA CSO LTCP Review Workshop December 8-9, 2004 Philadelphia, PA Presumption Approach Presumes that implementation of controls needed to meet defined performance criteria (e.g., controlling CSOs to no more than an average of four overflow events per year) would provide an adequate level of protection to meet the WQ-based objectives of the CWA. Minimum treatment defined as primary clarification or equivalent level of treatment. Framework for CSO Control Planning Framework for CSO Control Planning

Presumption Approach: Performance Criteria EPA CSO LTCP Review Workshop December 8-9, 2004 Philadelphia, PA Presumption Approach: Performance Criteria Reduction of CSO frequency to an average of 4 overflows per year (with discretion to add 2 additional overflows) Elimination or capture for treatment of 85% of the volume of combined sewage in CSS during precipitation events on an "average annual basis.” Elimination or capture for treatment of 85% of the mass of pollutants in CSS during precipitation events on an average annual basis. Note: Still requires post-construction compliance monitoring! Presumption approach relies on specific performance criteria. Note: Needs to be verified. Framework for CSO Control Planning Framework for CSO Control Planning

Phased Progress Under Presumption Approach Framework for CSO Control Planning

Demonstration Approach EPA CSO LTCP Review Workshop December 8-9, 2004 Philadelphia, PA Demonstration Approach Requires municipality to demonstrate that: The LTCP is adequate to meet WQ standards Remaining CSO discharges will not preclude attainment of WQ standards LTCP provides maximum pollutant reduction and benefits reasonably attainable Note: Generally provides for less control than Presumption Approach (< 85% capture) Framework for CSO Control Planning Framework for CSO Control Planning

Requires Wet Weather Surveys to Demonstrate Attainment of WQS Framework for CSO Control Planning

E coli example WQS is Geomean of 126 mpn/100ml Time Period August Geomean Station 1 August Geomean Station 2 August Geomean Station 3 Pre-CSO Control 528 398 203 August 2003 96 49 72 August 2004 114 98 36 Framework for CSO Control Planning

Framework for CSO Control Planning The Key Discuss the scope of LTCP with NPDES and WQS authority in advance to make sure that they will have sufficient information to identify the appropriate level of CSO control. Framework for CSO Control Planning

Success Requires Participation and Coordination Framework for CSO Control Planning