Framework for CSO Control Planning

1. Framework for CSO Control Planning Michael Sullivan Limno-Tech, Inc.

2. Material to be Covered • CSO Control Policy • Nine Minimum Controls (NMC) • Long-term Control Plans (LTCPs) • Small System Considerations Framework for CSO Control Planning

3. Gambles Hill CSO OutfallPrior to CSO Control (1996) Framework for CSO Control Planning

4. CSO Outfall Framework for CSO Control Planning

5. 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

6. 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

7. 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

8. 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

9. 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

10. 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

11. 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

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

13. NMC 2: Maximum use of the CSS for storage Framework for CSO Control Planning

14. Hospitals Photo processors Dry cleaners Laundries Auto body shops Dentists Garages Gas Stations Restaurants Landfill leachate Printers Car Washes 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: Framework for CSO Control Planning

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

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

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

18. NMC 7: Pollution prevention programs Framework for CSO Control Planning

19. NMC 8: Public notification Framework for CSO Control Planning

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

21. 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

22. 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 Nine Elements of an LTCP for Large CSO Communities Framework for CSO Control Planning

23. 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

24. 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

25. 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) Framework for CSO Control Planning

26. 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

27. 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! Framework for CSO Control Planning

28. Phased Progress Under Presumption Approach Framework for CSO Control Planning

29. 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

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

31. E coli exampleWQS is Geomean of 126 mpn/100ml Framework for CSO Control Planning

32. 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

33. Success Requires Participation and Coordination Framework for CSO Control Planning