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Sanitary Sewer Overflow Enforcement : a National Perspective

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Sanitary Sewer Overflow Enforcement : a National Perspective Sanitary Sewer Overflow Enforcement : A National Perspective LOREN DENTON, CHIEF MUNICIPAL ENFORCEMENT BRANCH WATER ENFORCEMENT DIVISION U.S. ENVIRONMENTAL PROTECTION AGENCY 2 Topics Covered SSOs – National Enforcement Initiative Collection System Violations Injunctive Relief Integrated Planning Financial Capability Recent SSO Settlements Background 3 ~20,000 sanitary sewer systems nationwide. 2004 Report to Congress on “Impacts and Control of CSOs and SSOs” EPA estimated: Annual SSO discharge volume at 3 to 10 billion gal/yr; 23,000 - 75,000 SSOs occur each year nationwide. Numbers low? Likely - SSO reporting requirements vary from state to state. 4 Sanitary Sewer Overflows Overflows To Waters of the U.S. That do not reach Waters of the U.S. Building/Property Backups. 4 Threat to Public Health and the 5 Environment Untreated sewage discharges contain: High concentrations of microbial pathogens; Industrial wastes; Hospital wastes. 5 6 http://www2.epa.gov/enforcement 7 Status of sanitary sewer systems 8 9 Collection System Violations Unpermitted discharges; Operation and Maintenance (O&M); Illegal bypasses at the wastewater treatment plant; “Imminent and substantial endangerment”; Section 504 of the CWA. Injunctive Relief 10 WWTP Optimization/Expansion; Flow Monitoring and Modeling; Sanitary Sewer Evaluation Survey; Excessive I/I Private Laterals Capacity Assessment; 1 Pump station replace/upgrade; 0 Injunctive Relief, cont. 11 Sewer line repairs/replacements; Overflow Reporting/Response Plan (including “Building Backup Program”); Asset Management; Elimination of constructed SSO outfalls. Next Gen Compliance; Civil penalties; Supplemental Environmental Projects (SEPs). 11 12 Integrated Planning Framework: What Does It Provide? An opportunity for municipalities to propose to meet CWA requirements by: sequencing wastewater and stormwater projects in a way that allows the highest priority environmental projects to come first, and potentially using innovative solutions, such as green infrastructure. Integrated Planning 13 Use the flexibility of EPA’s existing regulations and policies to encourage municipalities to evaluate how best to meet all of their CWA requirements: Maintain existing regulatory standards; Within a municipalities financial capability; Sequencing wastewater and stormwater projects, highest priority environmental projects come first Adaptive management; and, Innovative solutions, such as green infrastructure. 14 Integrated Plan Elements Element 1 ― Water Quality, Human Health, Regulatory Issues Element 2 ― Existing Systems and Performance Element 3 ― Stakeholder Involvement Element 4 ― Evaluating and Selecting Alternatives Element 5 ― Measuring success Element 6 ― Improvements to Plan 15 Financial Capability Financial issues often impact compliance schedule development. EPA’s approach to considering financial issues established in1997 Guidance: “Combined Sewer Overflows – Guidance for Financial Capability Assessment and Schedule Development. The guidance is also applicable to SSO and other municipal enforcement issues. 16 Financial Capability Framework FCA Framework, 2014: Elements 1997 Guidance provides a common basis. Financial capability is on a continuum - MHI (Median Household income) is not a rigid threshold. EPA will consider cost for all CWA obligations. Communities should assure that CWA obligations that are included as costs will be implemented. 17 Environmental Justice Untreated sewage overflows particularly affect older urban areas, where minority and/or low income communities are often concentrated. Certain areas of a community may be disproportionably impacted by the costs to implement environmental control measures. 18 Next Generation Compliance 19 20 Obligation to Perform Work Work performed using sound engineering practices …, including practices to improve the resilience of the Sewer System to the impacts of climate change. Sound engineering practices may include appropriate provisions of Handbook: Sewer System Infrastructure Analysis and Rehabilitation, EPA/625/6-91/030, 1991; Existing Sewer Evaluation and Rehabilitation, WEF MOP FD-6, 2010; Computer Tools for Sanitary Sewer System Capacity Analysis and Planning, EPA/600/R-07/111, October 2007; Applicable state Guidance for the Design of Publicly Owned Wastewater Facilities; EPA's Climate Ready Water Utilities (CRWU) Initiative, referenced at EPA 817-F-12-005, 2012; and EPA's Climate Resilience Evaluation and Awareness Tool Version 2.0 (CREAT 2.0), referenced at EPA 817-F- 12- 011, 2012 21 Examples of Injunctive Relief from Recent Cases Resolve by EPA/DOJ Bangor, ME Greenville, MS Bangor, ME 22 Lodged 8-26-15 Injunctive Relief Includes: CSO/SSO/MS4 Settlement Develop and Implement CMOM Program, including sewer system evaluations studies (“SSES”), Implementing a thorough IDDE program within the City’s MS4. 23 Greenville, MS Lodged 1-28-16 Injunctive Relief Includes: Evaluation and rehabilitation of the City’s wastewater collection system; Capacity assessment and remedial actions; Implementation of a Capacity, Management, Operation and Maintenance (CMOM) Program; and, All Work shall be performed using sound engineering practices to ensure … the Sewer System complies with the CWA, including practices to improve the resilience of the Sewer System to the impacts of climate change 24 Sanitary Sewer Overflow Enforcement A National Perspective Questions? LOREN DENTON WATER ENFORCEMENT DIVISION U.S. EPA 202-564-1148 [email protected] .
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